⚖ Oral Arguments, with Context

Scott and Audrey Blum challenge nearly sixteen million dollars in taxes tied to a 1999 BLIPS tax shelter. The Tax Court found that Blum used the DSIF partnership to inflate his tax basis and report a seventy-eight point five million dollar artificial loss, offsetting about seventy-four point eight million dollars from an unrelated sale. A district court upheld the partnership adjustments, and the IRS later issued personal deficiency notices. The Tax Court held them timely because DSIF's tax matters partner had extended the deadline and any challenge belonged in the earlier partnership case. The Blums say the Form 872-P in the record bears the partner's signature but not the IRS's, and that a limitations period is not a partnership item under TEFRA. The Commissioner says the consent was fully executed and TEFRA confined the defense to the partnership case. The Tenth Circuit must decide whether the Blums lost that defense and, if not, whether the deadline was validly extended.

Blum v. Commissioner of Internal Revenue (No. 25-9001) — U.S. Court of Appeals for the Tenth Circuit, argued September 15, 2026.