Legal Opinion
Arbitrage Trading, Llc v. United States
United States Court of Federal Claims
Decided January 30, 2013No. 06-202TPublishedCited by 3 opinions
1Opinion of the Court
Partnership Taxation; Court’s Jurisdiction to Determine Applicability of Accuracy-Related Penalty Under I.R.C. § 6662 in Partnership-Level Proceeding
OPINION
HEWITT, Chief Judge.
This partnership-level tax proceeding, concerning the 1999 tax year, is brought on behalf of Arbitrage Trading, LLC (Arbitrage or plaintiff) by notice partner of Arbitrage The Robert and Jayne Gunther 1999 Revocable Trust (the Gunther Trust), acting through grantor Robert Gunther. See Compl. for Readjustment of P’ship Items Under Code § 6226 (Complaint or Compl), Docket Number (Dkt. No.) 1, ¶ 3. Defendant is the United…
2Cases cited35 opinions
- Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
- McNutt v. General Motors Acceptance Corp.Supreme Court of the United States · 1936
- Gregory v. HelveringSupreme Court of the United States · 1935
- Mitchell v. MaurerSupreme Court of the United States · 1934
- Indium Corporation of America v. Semi-Alloys, Inc.Court of Appeals for the Federal Circuit · 1985
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3Cited by3 opinions
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
- Highpoint Tower Technology Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019
- Rochlis v. United StatesUnited States Court of Federal Claims · 2020