Legal Opinion
Ad Global Fund, Llc, by and Through North Hills Holding, Inc., a Partner Other Than the Tax Matters Partner v. United States
Court of Appeals for the Federal Circuit
Decided March 2, 2007No. 06-5046PublishedCited by 53 opinions
1Opinion of the Court
WHYTE, District Judge.
This case concerns the interpretation of two sections of the Internal Revenue Code (“IRC”), I.R.C. § 6229(a) and I.R.C. § 6501. Appellant AD Global Fund, LLC (“AD Global”) appeals from the judgment of the United States Court of Federal Claims. The Court of Federal Claims held that § 6229(a) provides an extension of time to the statute of limitations in § 6501 for assessing taxes on partnership items, not a separate statute of limitations for partnership items. AD Global Fund, LLC v. United States, 67 Fed.Cl. 657 (2005). Because we agree that § 6229(a) does not provide a…
2Cases cited6 opinions
- Barnhart v. Sigmon Coal Co.Supreme Court of the United States · 2002
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Andantech L.L.C. v. CommissionerCourt of Appeals for the D.C. Circuit · 2003
- U.S. Steel Group (A Unit of Usx Corporation)and Bethlehem Steel Corporation v. United States, and Ag Der Dillinger HuttenwerkeCourt of Appeals for the Federal Circuit · 2000
- Crnkovich v. United StatesCourt of Appeals for the Federal Circuit · 2000
1 more not listed; retrieve them via the Exa API.
3Cited by53 opinions
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- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Salman Ranch Ltd. v. United StatesCourt of Appeals for the Federal Circuit · 2009
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