Omega Forex Grp., LC v. United States

BRISCOE, Circuit Judge.

Plaintiff Omega Forex Group LC (Omega), appearing by and through partner Robert Flath (Flath), appeals from the district court's decision affirming two Notices of Final Partnership Administrative Adjustment (FPAA) issued by the Internal Revenue Service to Omega. The two FPAAs, on the basis of fraud at the partnership level, eliminated large losses reported by Omega on its tax returns for years 1998 and 1999, and imposed penalties on Omega. Exercising jurisdiction pursuant to 28 U.S.C. § 1291 , we affirm the district court's decision.

I

Factual background

a) The parties

Omega…