Legal Opinion

Grapevine Imports, Ltd. v. United States

United States Court of Federal Claims

Decided July 17, 2007No. 05-296TPublishedCited by 24 opinions

1Opinion of the Court

OPINION

ALLEGRA, Judge.

This is the second leg of a case having its genesis in a series of transactions that purportedly gave partners a substantial positive basis in their partnership interests, ultimately leading them to claim losses upon the disposition of those interests. Two sets of potential adjustments are at issue—one set relates to the partners’ 1999 taxable year, while the other involves their 2000 taxable year. As to the latter year, the court, in the first leg of this case, held that section 6229 of the Internal Revenue Code of 1986 (26 U.S.C.) (the Code) did not create an…

2Cases cited34 opinions

  1. Sony Corp. of America v. Universal City Studios, Inc.Supreme Court of the United States · 1984
  2. Pension Benefit Guaranty Corporation v. LTV Corp.Supreme Court of the United States · 1990
  3. Badaracco v. CommissionerSupreme Court of the United States · 1984
  4. Hohn v. United StatesSupreme Court of the United States · 1998
  5. Colony, Inc. v. CommissionerSupreme Court of the United States · 1958

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3Cited by24 opinions

  1. Salman Ranch Ltd. v. United StatesCourt of Appeals for the Federal Circuit · 2009
  2. Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
  3. Intermountain Insurance Service of Vail v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2011
  4. Home Concrete & Supply, LLC v. United StatesCourt of Appeals for the Fourth Circuit · 2011
  5. Burks v. United StatesCourt of Appeals for the Fifth Circuit · 2011

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