Legal Opinion

Tigers Eye Trading, LLC v. Comm'r

United States Tax Court

Decided February 13, 2012No. Docket No. 14510-05PublishedCited by 36 opinions

The stipulated decision in this Son of BOSS TEFRA partnership-level case, entered by the Court Dec. 1, 2009, was agreed to by R and the tax matters partner (TMP) of Tigers Eye Trading, LLC (Tigers Eye), with concurrence of participating partner (P), a partner other than TMP.

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The stipulated decision in this Son of BOSS TEFRA partnership-level case, entered by the Court Dec. 1, 2009, was agreed to by R and the tax matters partner (TMP) of Tigers Eye Trading, LLC (Tigers Eye), with concurrence of participating partner (P), a partner other than TMP. The first decision paragraph specifies that the partnership items of ordinary loss, other deductions, distributions of property, and capital contributions were reduced to zero as determined in the notice of final partnership administrative adjustment (FPAA) issued to Tigers Eye. The second decision paragraph, determining…

1Opinion of the Court

OPINION

Beghe, Judge:

Following entry of a stipulated decision on December 1, 2009, this Son of BOSS1 case remains before this Court on a motion to revise the decision. The motion was filed by participating partner A. Scott Logan Grantor Retained Annuity Trust I, A. Scott Logan, Trustee, a partner other than the tax matters partner. We refer to the trustee in his individual capacity as Mr. Logan and to the trust as Logan Trust I or participating partner.

Participating partner argues that the stipulated decision upholds adjustments in the final partnership administrative adjustment (FPAA) and…

2Cases cited94 opinions

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Ruhrgas Ag v. Marathon Oil Co.Supreme Court of the United States · 1999
  3. United States v. Mead Corp.Supreme Court of the United States · 2001
  4. United States v. CottonSupreme Court of the United States · 2002
  5. National Cable & Telecommunications Assn. v. Brand X Internet ServicesSupreme Court of the United States · 2005

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3Cited by36 opinions

  1. Candyce Martin 1999 Irrevocable Trust v. United StatesCourt of Appeals for the Ninth Circuit · 2014
  2. CNT Investors, LLC v. Comm'rUnited States Tax Court · 2015
  3. Petaluma FX Partners, LLC v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2015
  4. Bedrosian v. Comm'rUnited States Tax Court · 2014
  5. Greenwald v. Comm'rUnited States Tax Court · 2014

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