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IRVINE v. U.S.

No. 12-20523.

729 F.3d 455 (2013)

John A. IRVINE; Lynda Irvine; Kenneth L. Kraemer; Billy J. White; Ina J. White, Plaintiffs-Appellants v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

September 5, 2013.

Attorney(s) appearing for the Case

Thomas E. Redding, Sallie W. Gladney, Redding & Associates, P.C., Houston, TX, for Plaintiffs-Appellants.

Bethany Buck Hauser, Esq., Michael J. Haungs, Esq., Supervisory Attorney, U.S. Department of Justice, Washington, DC, Michael D. Powell, U.S. Department of Justice, Dallas, TX, for Defendant-Appellee.

Before SMITH, HAYNES, and GRAVES, Circuit Judges.

JAMES E. GRAVES, JR., Circuit Judge:

Billy and Ina White, John and Lynda Irvine, and Kenneth Kraemer1 (collectively "Taxpayers") assert that the Internal Revenue Service ("IRS") erroneously assessed additional taxes and interest against them in connection with their investments in various partnerships in the 1980s. Taxpayers seek refunds of the federal income taxes and penalty interest paid. Taxpayers assert that the IRS's assessment of...

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