River City Ranches # 1 Ltd. v. Commissioner Of Internal Revenue

401 F.3d 1136 RIVER CITY RANCHES # 1 LTD., Leon Shepard, Tax Matters Partner, River City Ranches # 2 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 3 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 4 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 5 Ltd., Leon Shepard, Tax Matters Partner, River City Ranches # 6 Ltd., Leon Shepard, Tax Matters Partner, et al., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 03-73853. United States Court of Appeals, Ninth Circuit. Argued and Submitted January 11, 2005. Filed March 25, 2005. Montgomery W. Cobb, Portland, OR, for the petitioners-appellants. Eileen J. O'Connor, Assistant Attorney General, Richard Farber, and Anthony T. Sheehan, Department of Justice, Appellate Section, Tax Division, Washington, D.C., for the respondent-appellee. Appeal from an Order of the United States Tax Court. Before BRIGHT, * TASHIMA, and CALLAHAN, Circuit Judges. BRIGHT, Circuit Judge. Introduction 1 We review here an extensive opinion and judgment of the Tax Court 1 relating to the tax returns of several affiliated sheep-breeding partnerships. We affirm in part, reverse in part,…