Legal Opinion
Marriott International Resorts, L.P. v. United States
United States Court of Federal Claims
Decided August 28, 2008No. Nos. 01-256T, 01-257TPublishedCited by 4 opinions
1Opinion of the Court
OPINION AND ORDER
LETTOW, Judge.
Pending before the court are cross-motions for summary judgment, filed by the parties in this partnership-taxation case.1 At issue is a claimed tax loss of $71,189,461 on the sale of Mortgage Notes, as manifested on a partnership tax return. This loss was the planned result of a series of transactions entered into by Marriott-affiliated entities with the intention of recognizing a tax loss based upon the premise that the obligation to close a short sale2 is not considered a liability for partnership-tax-basis purposes.3 The *293Internal Revenue Service (“IRS” or…
2Cases cited25 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Mingus Constructors, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
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3Cited by4 opinions
- Marriott International Resorts, L.P. v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Erbey Holding Corporation John R. Erbey Family Limited Partnership v. Blackrock Financial Management, Inc.Superior Court of The Virgin Islands · 2023
- Erbey Holding Corporation John R. Erbey Family Limited Partnership v. Blackrock Financial Management, Inc.Superior Court of The Virgin Islands · 2023
- Northern Colorado Water Conservancy District v. United StatesUnited States Court of Federal Claims · 2009