In a tax case where the IRS issued a Notice of Final Partnership Administrative Adjustment based on its determination that the defendants implemented an illegal tax shelter and misstated certain information on its tax documents which resulted in significant tax underpayments, district court did not err in finding that the defendants had reasonable cause for its tax position, and, consequently, that it was not subject to the accuracy-related penalty in 26 U.S.C. section 6662.
Read Am. Boat Co., LLC. v. US, No. 09-1109
Appeals from the United States District Court for the Southern District of Illinois
Argued May 28, 2009Decided October 1, 2009
Judges
Before Bauer, Flaum, and , Kanne, Circuit Judges
Opinion by Bauer, Circuit Judge
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