Legal Opinion
Prati v. United States
Court of Appeals for the Federal Circuit
Decided May 5, 2010No. 2008-5117, 2008-5129PublishedCited by 42 opinions
1Opinion of the Court
BRYSON, Circuit Judge.
These two federal tax cases raise complex questions pertaining to the taxation of transactions involving partnerships. Our analysis is relatively straightforward, however, because prior decisions of this court in related cases have dealt with and resolved several of the issues that are before us in these cases. Those decisions largely dictate the results we reach here.
I
The dispute in these cases relates to a number of limited partnerships managed by American Agri-Corp (“AMCOR”), a corporation that promoted tax shelter partnerships during the 1980s. The partnerships were…
2Cases cited11 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Cathleen Carmen Mary Whiting v. Peter L. Krassner, A/K/A Mike Cimino Peter KrassnerCourt of Appeals for the Third Circuit · 2004
- Andantech L.L.C. v. CommissionerCourt of Appeals for the D.C. Circuit · 2003
- Keener v. United StatesCourt of Appeals for the Federal Circuit · 2009
6 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Martin v. United StatesUnited States Court of Federal Claims · 2011
- Basr Partnership v. United StatesCourt of Appeals for the Federal Circuit · 2015
- Bush v. United StatesCourt of Appeals for the Federal Circuit · 2013
- Basr Partnership, by and Through, William F. Pettinati, Sr., Tax Matters Partner v. United StatesUnited States Court of Federal Claims · 2013
- McCann v. United StatesUnited States Court of Federal Claims · 2012
37 more not listed; retrieve them via the Exa API.