Cir

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

SNJ LIMITED; RITCHIE N. STEVENS; No. 20-70902

JULIE A. KEENE-STEVENS,

Petitioners-Appellants, Tax Ct. No. 11284-18 v.

COMMISSIONER OF INTERNAL OPINION

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Argued and Submitted November 17, 2021 Pasadena, California

Filed March 10, 2022

Before: Jay S. Bybee and Mark J. Bennett, Circuit Judges, and Joseph F. Bataillon, * District Judge.

Opinion by Judge Bennett; Concurrence by Judge Bataillon

* The Honorable Joseph F. Bataillon, United States District Judge for the District of Nebraska, sitting by designation. SUMMARY **

Tax

The panel affirmed the Tax Court’s dismissal for lack of jurisdiction of Ritchie N. Stevens and Julie A. Keene- Stevens’s untimely petition for redetermination of federal income tax deficiencies for the partnership SNJ Limited (“SNJ”).

In 2017 and 2018, the Commissioner of Internal Revenue issued SNJ Notices of Final Partnership Administrative Adjustment (“FPAA”) for tax years 2006 and 2008, addressed to various…