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08-1746 - SRK Wilshire Partners, LLC v. USA


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08-1746 - SRK Wilshire Partners, LLC v. USA
November 20, 2008
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Filed opinion of the court by Judge Flaum. We REVERSE the district court's holding. Joel M. Flaum, Circuit Judge; Ilana Diamond Rovner, Circuit Judge and Diane P. Wood, Circuit Judge. [08-1743, 08-1744, 08-1746, 08-1747, 08-1749, 08-1750]
December 4, 2008
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ORDER: The opinion of this Court issued on 11/20/2008 is corrected as follows: On page 2, first full paragraph, line 11 should read: Chevron framework. For the reasons explained below, we conclude that the statute is ambiguous and the Treasury Regulation is reasonable. We reverse the district court's holding and remand for the district court to consider taxpayers' remaining challenges to enforcement of the summonses. On Page 15, the Conclusion should now read: For the foregoing reasons, we REVERSE the district court's holding, and we REMAND for the district court to consider taxpayers' remaining challenges to enforcement of the summonses. [6076678-3] [08-1743, 08-1744, 08-1746, 08-1747, 08-1749, 08-1750]