U.S. Court of Appeals for the Tenth Circuit
Roth v. C.I.R.
This writing
- Type
- Opinion
- Filed
- April 29, 2019
- Case
- Roth v. C.I.R.
- Case status
- Decided
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Opening text
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McHUGH, Circuit Judge. The Roths appeal from a decision of the Tax Court imposing a 40% penalty for their gross misstatement of the value of a conservation easement they donated to a land trust in Colorado. The Roths primarily contend that, before imposing the penalty, the IRS failed to obtain written, supervisory approval for its "initial determination" of a penalty assessment as requi…
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