Legal Opinion
Alpha I, L.P. v. United States
United States Court of Federal Claims
Decided August 28, 2008No. Nos. 06-407 T to 06-411 T, 06-810 T, 06-811 TPublishedCited by 12 opinions
1Opinion of the Court
OPINION AND ORDER
HEWITT, Judge.
I. Background: The Original Complaints and the Amended Complaints
The original complaints in these consolidated cases were brought to challenge the adjustments of partnership items under Internal Revenue Code (I.R.C.) § 6226 for either or both of the tax years ended December 31, 2001 (tax year 2001) and December 31, 2002 (tax year 2002) on the grounds, as to Alpha I, L.P., as to tax year 2001, that there were no partnership liabilities under I.R.C. § 752, Complaint [of Alpha I, L.P.] for Readjustment of Partnership Items Under Code Section 6226 (Compl.) ¶40, or…
2Cases cited14 opinions
- National Labor Relations Board v. Sears, Roebuck & Co.Supreme Court of the United States · 1975
- Carl Zeiss Stiftung v. V. E. B. Carl Zeiss, JenaDistrict Court, District of Columbia · 1966
- V.E.B. Carl Zeiss, Jena, Steelmasters, Inc. And Ercona Corporation v. Ramsey Clark, Acting Attorney General of the United StatesCourt of Appeals for the D.C. Circuit · 1967
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
- United States of America and E. C. Talley, Special Agent, Internal Revenue Service v. Paul R. HodgsonCourt of Appeals for the Tenth Circuit · 1974
9 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Alpha I, L.P. v. United StatesUnited States Court of Federal Claims · 2008
- Sikorsky Aircraft Corp. v. United StatesUnited States Court of Federal Claims · 2012
- In re McKesson Governmental Entities Average Wholesale Price LitigationDistrict Court, N.D. California · 2009
- Fairholme Funds, Inc. v. United StatesUnited States Court of Federal Claims · 2016
- Ford Motor Co. v. United StatesUnited States Court of Federal Claims · 2010
7 more not listed; retrieve them via the Exa API.