Legal Opinion
Sala v. United States
Court of Appeals for the Tenth Circuit
Decided July 23, 2010No. 08-1333PublishedCited by 22 opinions
1Opinion of the Court
MURPHY, Circuit Judge.
I. INTRODUCTION
Appellee, Carlos Sala, participated in an investment program that included an initial phase designed primarily to generate a tax loss so as to offset over $60 million in income he earned during the 2000 tax year. Sala’s wholly owned S Corporation, Solid Currencies, Inc. (“Solid”), acquired a combination of long and short foreign currency options and contributed them to a partnership. Under a pre-determined plan, the partnership existed for only a few weeks and was liquidated before year’s end. Relying on the rule from Helmer v. Comm’r, 34 T.C.M. (CCH) 727…
2Cases cited8 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- The Black & Decker Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 2006
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Rogers v. United StatesCourt of Appeals for the Tenth Circuit · 2002
- Nicole Rose Corp., Formerly Known as Quintron Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2003
3 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Reddam v. CommissionerCourt of Appeals for the Ninth Circuit · 2014
- Bank of N.Y. Mellon Corp. v. Comm'rUnited States Tax Court · 2013
- John Hancock Life Ins. Co. (U.S.A.) v. Comm'rUnited States Tax Court · 2013
- Bergmann v. CommissionerUnited States Tax Court · 2011
- Reddam v. Comm'rUnited States Tax Court · 2012
17 more not listed; retrieve them via the Exa API.