Legal Opinion
Jade Trading, LLC ex rel. Ervin Capital, LLC v. United States
United States Court of Federal Claims
Decided December 21, 2007No. 03-2164TPublishedCited by 54 opinions
1Opinion of the Court
OPINION
WILLIAMS, Judge.
Introduction
This tax refund case presents the issue of whether investments of $450,000 which generated over $40 million in tax losses possessed economic substance. In 1999, the Er-vin brothers sold their cable business, netting over $40 million in profit. That same year, each of the three Ervin brothers, through his limited liability corporation (LLC), simultaneously purchased a euro option from AIG for a premium of $15,000,020 and sold a euro option to AIG for a premium of $14,850,018 but only paid AIG the difference—a net premium of $150,002. Each LLC contributed the…
2Cases cited62 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Neely v. CommissionerUnited States Tax Court · 1985
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. CorrellSupreme Court of the United States · 1967
57 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Marriott International Resorts, L.P. v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Kornman & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2008
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- American Boat Co., LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2009
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