Legal Opinion
RERI Holdings I, LLC, Harold Levine, Tax Matters Partner v. Commissioner
United States Tax Court
Decided August 11, 2014No. 9324-08Published
1Opinion of the Court
143 T.C. No. 3
UNITED STATES TAX COURT RERI HOLDINGS I, LLC, HAROLD LEVINE, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9324-08. Filed August 11, 2014. LLC1 contributed a successor member interest in a second LLC (LLC2) to University. R moves for partial summary judgment that (1) the actuarial tables under I.R.C. sec. 7520 do not apply to value the successor member interest and (2) TMP failed to substantiate the value of the successor member interest with a qualified appraisal as defined in sec. 1.170A-13(c)(3), Income Tax Regs. Held: Pierre v.…
2Cases cited19 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Bond v. CommissionerUnited States Tax Court · 1993
- Commissioner v. SimmonsCourt of Appeals for the D.C. Circuit · 2011
- Ronald D. Smart, Doing Business as Paschall Electric v. International Brotherhood of Electrical Workers, Local 702Court of Appeals for the Seventh Circuit · 2003
- Weller v. CommissionerUnited States Tax Court · 1962
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