Cir

FOR PUBLICATION

UNITED STATES COURT OF APPEALS

FOR THE NINTH CIRCUIT

SEAVIEW TRADING, LLC, AGK No. 20-72416

INVESTMENTS, LLC, TAX MATTERS

PARTNER, Tax Ct. No. Petitioner-Appellant, 1837-

v.

OPINION

COMMISSIONER OF INTERNAL

REVENUE,

Respondent-Appellee.

Appeal from a Decision of the United States Tax Court

Argued and Submitted October 18, 2021 San Francisco, California

Filed May 11, 2022

Before: Bridget S. Bade and Patrick J. Bumatay, Circuit Judges, and William K. Sessions III, * District Judge.

Opinion by Judge Bumatay; Dissent by Judge Bade

* The Honorable William K. Sessions III, United States District Judge for the District of Vermont, sitting by designation. SUMMARY **

Tax

The panel reversed the Tax Court’s summary judgment in favor of the government, in a petition challenging a Final Partnership Administrative Adjustment and involving whether the three-year limitations period for adjustment of partnership losses under 26 U.S.C. § 6229(a) had begun to run, and remanded for further proceedings.

Taxpayer Seaview Trading, LLC, a California-based limited…