Taxpayers Call Return Filing Decision ‘Internally Inconsistent’

Two taxpayers argued in a rehearing request that an appeals court’s decision to reverse their US Tax Court victory was “internally inconsistent” in its handling of asserted partnership losses based on their failure to sign and file tax returns.

Ritchie Stevens and Julie Keene-Stevens said the three-judge Ninth Circuit panel that ruled against them July 3 recognized that the Tax Court had acknowledged the existence of their asserted partnership losses when it said it lacked jurisdiction to rule on the validity of those assertions.

It didn’t make sense for the panel to then argue that, because no tax returns were ...