Cases

PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT No. 21-1583 ARTHUR BEDROSIAN, Appellant v. THE UNITED STATES OF AMERICA, DEPARTMENT OF THE TREASURY, INTERNAL REVENUE SERVICE ________________ Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civ

AMBRO, Circuit Judge This appeal presents two issues of first impression in our Court concerning the Internal Revenue Service's assessment of civil penalties for violation of 31 U.S.C. § 5314 and its implementing regulations, which require certain persons annually to file a Report of F

PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________ No. 21-1935 _____________ UNITED STATES OF AMERICA v. RICHARD COLLINS, Appellant _____________ On Appeal from the United States District Court for the Western Distr

TJOFLAT, Circuit Judge: As many of us do, John and Joan Finnegan ("Taxpayers") hired someone to prepare their tax returns. For eight years, Taxpayers' return preparer included bogus claims on their returns. Taxpayers apparently were oblivious to this. The return preparer was indicted for his fraudulent behavior and pled guilty. Eventually, the IRS came calling: to recover the money it

Tax case; claim for refund of individual income taxes paid pursuant to a notice by the IRS of computational adjustments following an audit of a partnership return; submission by a non-tax matters partner of an administrative adjustment request (“AAR”) on Form 8082; compliance with instructions attendant to Form 8082; effect of I.R.C. §§ 6227(d), 6228(b)(2)(A)(i), 7422(h), Treasury Reg. § 301.6227(d) — 1; jurisdicti

PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________ No. 22-1122 __________ HOME DEPOT USA, INC., Appellant v. LAFARGE NORTH AMERICA, INC. _______________________ On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. Civil No.

OPINION ALLEGRA, Judge. Plaintiffs were limited partners in an “agricultural” partnership that generated large “farming” expense deductions for its partners in its first year of operation. After an audit and in settlement of a succeeding lawsuit, the partnership agreed to the disallowance of a portion of those deductions as, inter alia, lacking in economic substance. Plaintiffs essentially agreed t

United States Tax Court 163 T.C. No. 8 RAJU J. MUKHI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket No. 4329-22L. Filed November 18, 2024. ————— P failed to file Forms 5471, Information Return of