Superior Trading, LLC v. Comm'r
United States Tax Court
R denied losses claimed by Ps, tax matters or other participating partners on behalf of purported partnerships, relating to distressed consumer receivables acquired from a Brazilian retailer in bankruptcy reorganization. R adjusted partnership items, attributing a zero basis to the receivables in lieu of the claimed carryover basis in the full face amount of the receivables.
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R denied losses claimed by Ps, tax matters or other participating partners on behalf of purported partnerships, relating to distressed consumer receivables acquired from a Brazilian retailer in bankruptcy reorganization. R adjusted partnership items, attributing a zero basis to the receivables in lieu of the claimed carryover basis in the full face amount of the receivables. R determined accuracy-related penalties under sec. 6662(h), I.R.C., for gross valuation misstatements of inside bases. Held: Ps failed to establish that the distressed consumer receivables had any tax basis upon transfer…
1Opinion of the Court
SUPERIOR TRADING, LLC, JETSTREAM BUSINESS LIMITED, TAX MATTERS PARTNER, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Superior Trading, LLC v. Comm'r
Docket Nos. 20171-07, 20230-07, 20232-07, 20243-07, 20337-07, 20338-07, 20652-07, 20653-07, 20654-07, 20655-07, 20867-07, 20870-07, 20871-07, 20936-07, 19543-08.
United States Tax Court
137 T.C. 70; 2011 U.S. Tax Ct. LEXIS 38; 137 T.C. No. 6;
September 1, 2011, Filed
Decisions will be entered for respondent.
R denied losses claimed by Ps, tax matters or other participating partners on behalf of purported partnerships, relating to…
2Cases cited34 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
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