Legal Opinion
106 Ltd. v. Commissioner, IRS
Court of Appeals for the D.C. Circuit
Decided June 22, 2012No. 11-1242PublishedCited by 40 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge HENDERSON.
KAREN LeCRAFT HENDERSON, Circuit Judge:
106 Ltd. (Partnership), a limited partnership, appearing through its tax matters partner David Palmlund (Palmlund), appeals a decision of the United States Tax Court (Tax Court) upholding the imposition of a forty per cent accuracy-related penalty by the Internal Revenue Service (IRS). See 106 Ltd. v. Comm’r, 136 T.C. 67 (2011). The IRS determined that the Partnership had utilized a so-called “Son of BOSS” tax shelter to overstate its basis in Partnership interests by approximately $3 million and to…
2Cases cited13 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- United States v. BoyleSupreme Court of the United States · 1985
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
8 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
- William E. Gustashaw, Jr. v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
- In re WylyUnited States Bankruptcy Court, N.D. Texas · 2016
- NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014
- CNT Investors, LLC v. Comm'rUnited States Tax Court · 2015
35 more not listed; retrieve them via the Exa API.