Legal Opinion
Schumacher Trading Partners II v. United States
United States Court of Federal Claims
Decided July 31, 2006No. 05-380TPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
BRADEN, Judge.
On October 22, 2004, the Internal Revenue Service (“IRS”) issued a Notice of Final Partnership Administrative Adjustment (“FPAA”), pursuant to 26 U.S.C. § 6223, to the Schumacher Trading Partners II partnership. Plaintiffs filed this action to contest this adjustment.
The parties’ cross-motions for summary judgment require the court to interpret a provision of the Internal Revenue Code, 26 U.S.C. § 6229(a), and determine whether the FPAA was issued within the time period during which Congress authorized the IRS to adjust a partnership return and…
2Cases cited34 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Exxon Mobil Corp. v. Allapattah Services, Inc.Supreme Court of the United States · 2005
- Alexander v. SandovalSupreme Court of the United States · 2001
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3Cited by3 opinions
- Kislev Partners, L.P. v. United StatesUnited States Court of Federal Claims · 2008
- Russian Recovery Fund Ltd. v. United StatesUnited States Court of Federal Claims · 2009
- Ginsburg v. Comm'rUnited States Tax Court · 2006