Nevada Partners Fund, L.L.C. v. United States

JAMES L. DENNIS, Circuit Judge:

This appeal arises from eleven notices of final partnership administrative adjustment (FPAAs) issued by the IRS with respect to three Limited Liability Companies (LLCs) treated as partnerships for tax purposes: 1 Nevada Partners Fund, LLC (“Nevada”), Carson Partners Fund (“Carson”), and Reno Partners Fund, LLC (“Reno”) (collectively, the “plaintiffs” or “partnerships”). See 26 U.S.C. §§ 6223, 6226(a). The FPAAs eliminated approximately $18 million of claimed tax losses and determined that penalties were applicable. According to the IRS, the partnerships’…