SNJ Limited, et al v. CIR
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March 10, 2022
9th Circ. Tosses Partnership's Untimely Tax Challenge
A partnership cannot challenge IRS tax adjustments after the Ninth Circuit found Thursday that its U.S. Tax Court suit was untimely because it was filed more than 150 days after it received the first of two sets of agency adjustments.
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June 03, 2021
Partnership's Adjustment Challenge Untimely, 9th Circ. Told
A partnership's challenge to an Internal Revenue Service tax adjustment was untimely because it was filed more than 150 days after the agency issued its first notice alerting the entity to the adjustments, the U.S. government told the Ninth Circuit.
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April 05, 2021
Partnership's Adjustment Challenge Timely, 9th Circ. Told
A partnership's challenge to an Internal Revenue Service tax adjustment was timely because it was filed within 90 days after the agency sent a notice detailing the changes, the partnership told the Ninth Circuit in a brief.