Legal Opinion

3K Inv. Partners v. Comm'r

United States Tax Court

Decided September 3, 2009No. 3891-06Published

In this partnership-level proceeding involving a so-called Son-of-BOSS transaction, P has moved to compel R to produce redacted copies of all tax opinions collected by R that have been issued regarding Son-of-BOSS transactions, as well as a list of the names and addresses of all law firms and accounting firms known to R to have issued tax opinion letters regarding Son-of-BOSS transactions.

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In this partnership-level proceeding involving a so-called Son-of-BOSS transaction, P has moved to compel R to produce redacted copies of all tax opinions collected by R that have been issued regarding Son-of-BOSS transactions, as well as a list of the names and addresses of all law firms and accounting firms known to R to have issued tax opinion letters regarding Son-of-BOSS transactions. Held: Because the materials that P seeks to discover are not relevant and do not appear reasonably calculated to lead to discovery of admissible evidence, and because the materials are nondisclosable…

1Opinion of the Court

3K INVESTMENT PARTNERS, 3K INVESTMENTS LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

3K Inv. Partners v. Comm'r

No. 3891-06

United States Tax Court

133 T.C. 112; 2009 U.S. Tax Ct. LEXIS 23; 133 T.C. No. 6;

September 3, 2009, Filed

In this partnership-level proceeding involving a so-called Son-of-BOSS transaction, P has moved to compel R to produce redacted copies of all tax opinions collected by R that have been issued regarding Son-of-BOSS transactions, as well as a list of the names and addresses of all law firms and accounting firms known to R to have…

2Cases cited18 opinions

  1. Tax Analysts v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1997
  2. Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
  3. Church of Scientology v. Internal Revenue ServiceSupreme Court of the United States · 1987
  4. Kligfeld Holdings v. Comm'rUnited States Tax Court · 2007
  5. United States of America and Ralph L. Guyette, Special Agent, Internal Revenue Service v. John B. HarringtonCourt of Appeals for the Second Circuit · 1968

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