Legal Opinion
Seaview Trading, LLC v. Commissioner
Court of Appeals for the Ninth Circuit
Decided June 7, 2017No. 15-71330PublishedCited by 8 opinions
1Opinion of the Court
OPINION
M. SMITH, Circuit Judge:
This appeal presents the question of whether entities that are disregarded for federal tax purposes may nevertheless constitute pass-thru partners under 26 U.S.C. § 6231(a)(9) such that their partnership is not eligible for the small-partnership exception contained in § 6231. For the reasons stated in this opinion, we hold that an entity’s disregarded status does not preclude its classification as a pass-thru partner.
FACTUAL AND PROCEDURAL BACKGROUND
In 2001, Robert Kotick (Kotick) and his father Charles Kotick (C. Kotick) formed a Delaware limited liability…
2Cases cited17 opinions
- Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- City of Revere v. Massachusetts General HospitalSupreme Court of the United States · 1983
- Hecht v. MalleySupreme Court of the United States · 1924
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3Cited by8 opinions
- Mellow Partners, A Partnership v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2018
- Seaview Trading, LLC, Agk Inve v. CirCourt of Appeals for the Ninth Circuit · 2023
- Multnomah Cnty., an Existing Cnty. Gov'T&a Body Politic & Corporate v. AzarDistrict Court, D. Oregon · 2018
- Seaview Trading, LLC, Agk Inve v. CirCourt of Appeals for the Ninth Circuit · 2022
- Dewayne Bridges v. CommissionerUnited States Tax Court · 2020
3 more not listed; retrieve them via the Exa API.