In a consolidated appeal of orders of the United States Tax Court assessing income deficiencies against former business partners engaged in an abusive tax shelter known as "Son-of-Boss", the tax court had jurisdiction over the deficiency proceedings but the case is remanded for consideration of whether certain components of the deficiencies were time-barred.
Argued: March 10, 2009
Decided and Filed: September 17, 2009
Opinion by Judge Gibbons
For Appellant: David D. Aughtry, Chamberlain, Hrdlicka, White, Williams & Martin, Atlanta, Georgia.
For Appellee: Michael J. Haungs, United States Department of Justice, Washington, D.C.