Legal Opinion
Alpha I, L.P. Ex Rel. Sands v. United States
Court of Appeals for the Federal Circuit
Decided June 15, 2012No. 2011-5024, 2011-5030PublishedCited by 15 opinions
1Opinion of the Court
O’MALLEY, Circuit Judge.
The U.S. Court of Federal Claims dismissed the Internal Revenue Service’s determination that certain taxpayers’ transfers of their partnership interests to trusts were shams because the court believed it lacked jurisdiction to address the IRS’s determination at the partnership level. The United States appeals that ruling in Case No. 2011-5024. We reverse the Court of Federal Claims’s dismissal. The identity of the true partners in the partnership at issue appropriately is determined at the partnership level because, on the particular facts of this case, partnership…
2Cases cited28 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- McCrary v. CommissionerUnited States Tax Court · 1989
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
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3Cited by15 opinions
- William E. Gustashaw, Jr. v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
- Kerman v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
- Basr Partnership v. United StatesCourt of Appeals for the Federal Circuit · 2015
- Jeff Blau, Tax Matters Partner of RERI Holdings I, LLC v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2019
- AHG Invs., LLC v. Comm'rUnited States Tax Court · 2013
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