Curr-Spec Prts, LP v. CIR

REVISED September 4, 2009 IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT United States Court of Appeals Fifth Circuit FILED No. 08-60815 August 11, 2009 Charles R. Fulbruge III Clerk CURR-SPEC PARTNERS, L.P. Petitioner-Appellant v. COMMISSIONER OF INTERNAL REVENUE Respondent-Appellee Appeal from a decision of the United States Tax Court Before REAVLEY, WIENER, and SOUTHWICK, Circuit Judges. JACQUES L. WIENER, JR., Circuit Judge: Petitioner-Appellant Curr-Spec Partners, L.P. (“Curr-Spec”), asks us to interpret the interplay between the limitation provisions of Internal Revenue…