Supreme Court of the United States · Official docket →
Ritchie N. Stevens, et al. v. Commissioner of Internal Revenue
Paid petition · United States Court of Appeals for the Ninth Circuit, No. 21-71082 · judgment July 3, 2023
Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.
Questions presented
-
Whether a net operating loss carryover to a future year that is an “affected item” under the TEFRA Partnership audit regime can be included within the definition of a “net loss from partnership items” for purposes of former 26 U.S.C. §6234(a)(3), given that the definitions of “partnership items” and “affected items” are mutually exclusive.
-
Whether the submission of unsigned partnership tax returns and unsigned personal tax returns of the partners to the IRS and the Tax Court was sufficient for the Tax Court to acknowledge the asserted partnership losses reflected on those returns for purposes of resolving the partners’ Tax Court case.
Counsel of record
For petitioner
A. Lavar Taylor
Taylor Nelson Amitrano LLP
For respondent
Elizabeth B. Prelogar
Solicitor General
Case
Conference history
Distributed for 1 conference
Proceedings
- Feb 20 2024Petition DENIED.
- Jan 17 2024DISTRIBUTED for Conference of 2/16/2024.
- Jan 10 2024Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
- Dec 13 2023Petition for a writ of certiorari filed. (Response due January 16, 2024)