Legal Opinion
Jade Trading, LLC Ex Rel. Ervin v. United States
Court of Appeals for the Federal Circuit
Decided March 23, 2010No. 2008-5045PublishedCited by 43 opinions
1Opinion of the Court
ARCHER, Circuit Judge.
Jade Trading, LLC (“Jade”) appeals the Court of Federal Claims’ denial of its petition for readjustment of the partnership items of Jade and its affirmance of the Internal Revenue Service’s (“IRS” or “Service”) application of penalties at the partnership level without consideration of the partners’ reasonable cause defense. Jade Trading v. United States, 80 Fed.Cl. 11 (2007). Because the contribution of euro call options to Jade (hereinafter sometimes called the spread transaction) was a transaction that lacked economic substance, we affirm the Court of Federal Claims’…
2Cases cited12 opinions
- United States v. Alaska Steamship Co.Supreme Court of the United States · 1920
- Distributed Solutions, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2008
- Acs Hospital Systems, Inc., Appellant/cross-Appellee v. Montefiore Hospital and Wells National Services Corporation, Appellees/cross-AppellantsCourt of Appeals for the Federal Circuit · 1984
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
7 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- United States v. WoodsSupreme Court of the United States · 2013
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Martin v. United StatesUnited States Court of Federal Claims · 2011
38 more not listed; retrieve them via the Exa API.