Keller v. Commissioner
Court of Appeals for the Ninth Circuit
1Opinion of the Court
RYMER, Circuit Judge:
These consolidated appeals concern the outstanding tax liabilities for sixteen Taxpayers (as we shall refer to the individual partners) who invested in cattle partnerships operated by Walter J. Hoyt III. Their appeals are taken from the decision of the Tax Court holding that the Commissioner of Internal Revenue did not abuse his discretion in rejecting Taxpayers’ offers-in-compromise. In collection due process hearings Taxpayers also challenged the imposition of interest under former 26 U.S.C. § 6621(c). 1 The Tax Court held that it lacked jurisdiction in partner-level…
2Cases cited25 opinions
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