- 2 - Docket Nos. 787-91, 4876-94, Filed July 2, 2007. 9550-94, 9552-94, 9554-94, 13595-94, 13597-94, 13599-94, 14038-96. Montgomery W. Cobb, for petitioners. Terri A. Merriam, for participating partners in docket Nos. 9554-94 and 13599-94. Catherine J. Caballero, Thomas N. Tomashek, Gregory M. Hahn, Nhi Luu, and Dean H. Wakayama, for respondent. SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge: These cases are now before the Court on remand from the U.S. Court of Appeals for the Ninth Circuit. River City Ranches #1 Ltd. v. Commissioner, 401 F.3d 1136 (9th Cir. 2005) (River City Ranches II), affg. in part, revg. in part and remanding T.C. Memo. 2003-150 (River City Ranches I). The Court of Appeals concluded that we erred in holding that we lacked jurisdiction to make findings concerning the character of the partnerships’ transactions for purposes of the penalty- interest provisions of section 6621(c)2 and mandated that we make such findings. The Court of Appeals also directed us to permit 2Unless otherwise indicated, section references herein are to the Internal Revenue Code in effect for the taxable years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007