Legal Opinion
Levin v. United States
District Court, D. Maryland
Decided September 13, 2017No. Civil Action No. PX 15–1880Published
1Opinion of the Court
26 U.S.C. § 6231(a)(3). Treasury Regulation § 301.6231(a)(3)-1 further identifies partnership items as the income, gains, losses, deductions and credits of a partnership.
*71326 C.F.R. § 301.6231(a)(3)-1 ; see also Prochorenko v. United States , 243 F.3d 1359, 1363 (Fed. Cir. 2001) ; Keener v. United States , 76 Fed.Cl. 455, 458 (2007). A partnership item also includes factors that affect the determination of partnership items such as "accounting practices and the legal and factual determinations that underlie the determination of the amount, timing, and characterization of items of income, credit,…
2Cases cited16 opinions
- Adams v. JohnsonCourt of Appeals for the Ninth Circuit · 2004
- United States v. Clintwood Elkhorn Mining Co.Supreme Court of the United States · 2008
- Computer Programs Lambda, Ltd. v. CommissionerUnited States Tax Court · 1987
- Abel Kaplan and Mary Lou Kaplan v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Keener v. United StatesCourt of Appeals for the Federal Circuit · 2009
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