Presidio Advisors, LLC v. United States

OPINION

ALLEGRA, Judge:

In this action, petitioners, Presidio Advis-ors, LLC (Presidio) and Norvest Limited, challenge the IRS’ disallowance of $11.4 million in losses claimed by Presidio on its 1998 federal tax return and the assessment of accuracy-related penalties based on the resulting underpayment of tax. Respondent has filed a motion for partial summary judgment on the issue whether Presidio is entitled to a carry-over basis in equipment it acquired from another entity, the sale of which equipment was used to justify the challenged $11.4 million loss. Resolution of this issue requires the…