Legal Opinion
Russian Recovery Fund Limited v. United States
Court of Appeals for the Federal Circuit
Decided March 14, 2017No. 2016-1718, 2016-1719 2016-1719PublishedCited by 7 opinions
1Opinion of the Court
Wallach, Circuit Judge.
Appellant Russian Recovery Fund Limited (“RRF”), acting through its tax matters partners Russian Recovery Advisers, L.L.C. (“RRA”)' and Bracebridge Capital, L.L.C. (“Bracebridge”), sued the United States (“the Government”) in the U.S. Court of Federal Claims, seeking readjustment of partnership items pursuant to the Tax Equity and Fiscal Responsibility Act (“TEFRA”), I.R.C. §§ 6221-6233 (2000). RRF alleges that the Internal Revenue Service’s (“the IRS”) October 14, 2005 Notice of Final Partnership Administrative Adjustment (“2005 FPAA”) improperly disallowed…
2Cases cited31 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Dickerson v. United StatesSupreme Court of the United States · 2000
- United States v. BoyleSupreme Court of the United States · 1985
- Gustafson v. Alloyd Co.Supreme Court of the United States · 1995
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
26 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Jarnagin v. United StatesUnited States Court of Federal Claims · 2017
- Alternative Carbon Resources v. United StatesCourt of Appeals for the Federal Circuit · 2019
- City of Fresno v. United StatesCourt of Appeals for the Federal Circuit · 2024
- General Mills, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2020
- Leighton v. United StatesUnited States Court of Federal Claims · 2021
2 more not listed; retrieve them via the Exa API.