Irvine, et al. v. United States

This tax refund suit is one among several arising from a series of limited partnerships managed by AMCOR in the 1980s. Taxpayers asserted that the IRS erroneously assessed additional taxes and interest against them in connection with their investments in various partnerships in the 1980s and sought refunds of the federal income taxes and penalty interest paid. The court held that the district court lacked jurisdiction over the statute of limitations claims. Concluding that the district court did have jurisdiction over the penalty claims, the court held that, under Weiner v. United States, the assessment penalty interest against taxpayers was erroneous as a matter of law. Accordingly, the court reversed the district court's grant of summary judgment for the government and rendered judgment for taxpayers on this issue. View "Irvine, et al. v. United States" on Justia Law