Acute Care Specialists v. U.S.

Dist. Ct. did not err in dismissing for lack of subject-matter jurisdiction plaintiffs-taxpayers’ challenge to IRS deficiency assessments, that included penalty interest, where IRS had disallowed certain farming expenses arising out of plaintiffs’ partnerships after finding that plaintiffs’ partnerships were essentially tax-avoidance schemes, even though plaintiffs had asserted that limitations period under 26 USC section 6229(a) had expired prior to IRS issuing its Final Partnership Administration Adjusts. Dist. Ct. could properly find that plaintiffs’ statute of limitations argument that concerned claim that IRS and tax-matter partner in partnerships did not agree to extend applicable limitations period, as well as their challenge to IRS’s penalty interest assessments, involved partnership-level determinations that precluded plaintiffs from bringing instant challenge under 26 USC section 7422(h).