Legal Opinion
Roth v. C.I.R.
Court of Appeals for the Tenth Circuit
Decided April 29, 2019No. 18-9006PublishedCited by 5 opinions
1Opinion of the Court
McHUGH, Circuit Judge.
The Roths appeal from a decision of the Tax Court imposing a 40% penalty for their gross misstatement of the value of a conservation easement they donated to a land trust in Colorado. The Roths primarily contend that, before imposing the penalty, the IRS failed to obtain written, supervisory approval for its "initial determination" of a penalty assessment as required by I.R.C. § 6751(b). The Roths also seek a deduction in 2007 for repayments they made on the proceeds from their sale of tax credits generated by their donation of a separate conservation easement in 2006.…
2Cases cited22 opinions
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Green v. Bock Laundry MacHine Co.Supreme Court of the United States · 1989
- Federal Trade Commission v. Mandel Bros.Supreme Court of the United States · 1959
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3Cited by5 opinions
- Laidlaw's Harley Davidson Sale v. CirCourt of Appeals for the Ninth Circuit · 2022
- Choong H. Koh v. CommissionerUnited States Tax Court · 2020
- Laidlaw's Harley Davidson Sales, Inc. v. CommissionerUnited States Tax Court · 2020
- Sunil S. Patel & Laurie McAnally Patel v. CommissionerUnited States Tax Court · 2020
- Ugorji Timothy Wilson Onyeani v. CommissionerUnited States Tax Court · 2020