Am. Boat Co., LLC. v. US, No. 09-1109

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, 2009
Decided October 1, 2009

Judges

Before Bauer, Flaum, and , Kanne, Circuit Judges

Opinion by Bauer, Circuit Judge