9th Cir.;
15-15551

The court of appeals affirmed a district court judgment. The court held that an alleged third-party conflict of interest did not invalidate a taxpayer's consent to extension of the limitations period for assessing delinquent taxes.

In 2002, the Internal Revenue Service launched an investigation of an elaborate tax sheltering scheme tied to various investment funds. In 2003, while the investigation was underway, the IRS approached individual investor Tom Gonzales, who had invested in the Logan Strategic Investment Fund. Logan filed its 2000 partnership tax return on April 16, 2001, so absent an extension of the statute of limitations, the IRS had until April 16, 2004, to assess any taxes with respect to that return. The IRS asked Gonzales to execute consents extending the limitations period to June 30, 2005. Gonzales agreed. The IRS filed an adjustment for Logan in April 2005.