Legal Opinion
Jade Trading, LLC v. United States
United States Court of Federal Claims
Decided March 20, 2008No. 03-2164TPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER DENYING MOTION FOR RECONSIDERATION FILED BY SENTINEL ADVISORS, LLC1
WILLIAMS, Judge.
This matter comes before the Court on a motion for reconsideration filed by Sentinel Advisors, LLC (Sentinel).2 In the underlying decision, this Court found that spread transactions contributed to a partnership which generated substantial tax losses lacked economic substance and had to be disregarded for tax purposes,—a finding which triggered the application of four alternative statutory penalties.
Sentinel seeks reconsideration of one narrow aspect of this Court’s opinion—the…
2Cases cited14 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Caldwell, Iii v. United StatesCourt of Appeals for the Federal Circuit · 2004
- Yuba Natural Resources, Inc. v. The United States, Defendant/cross-AppellantCourt of Appeals for the Federal Circuit · 1990
- Fru-Con Construction Corp. v. United StatesUnited States Court of Federal Claims · 1999
- Matthews v. United StatesUnited States Court of Federal Claims · 2006
9 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Consolidated Edison Co. v. United StatesUnited States Court of Federal Claims · 2009
- Kislev Partners, L.P. v. United StatesUnited States Court of Federal Claims · 2008
- Jade Trading, LLC v. United StatesUnited States Court of Federal Claims · 2011