Legal Opinion
Knudsen v. Commissioner
Court of Appeals for the Ninth Circuit
Decided July 15, 2015No. 13-72077PublishedCited by 12 opinions
1Opinion of the Court
OPINION
WALTER, District Judge:
In this case, we are asked to decide whether a unilateral concession by the Internal Revenue Service (“IRS”) is a settlement, for purposes of the Qualified Offer Rule (“QOR”) of the Internal Revenue Code, codified at 26 U.S.C. § 7430(e)(4)(E). We conclude that this concession was not a settlement, within the meaning of .the QOR. Accordingly, we reverse the decision of the United States Tax Court and remand the case for a determination of reasonable attorney’s fees and costs to be awarded to the taxpayer, as the prevailing party.
I. FACTUAL AND PROCEDURAL HISTORY
The…
2Cases cited13 opinions
- Circuit City Stores, Inc., a Virginia Corporation v. Monir NajdCourt of Appeals for the Ninth Circuit · 2002
- Jeff D. v. AndrusCourt of Appeals for the Ninth Circuit · 1990
- Adkison v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
- Suzy's Zoo (R) v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- Custom Chrome, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
8 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Laidlaw's Harley Davidson Sale v. CirCourt of Appeals for the Ninth Circuit · 2022
- Patients Mutual Assistance v. CirCourt of Appeals for the Ninth Circuit · 2021
- Angle v. Comm'rUnited States Tax Court · 2016
- Celia Mazzei v. CirCourt of Appeals for the Ninth Circuit · 2021
- Crystal N. Greenwald v. United States of AmericaDistrict Court, S.D. Ohio · 2025
7 more not listed; retrieve them via the Exa API.