Legal Opinion

Tigers Eye Trading, LLC v. Comm'r

United States Tax Court

Decided February 13, 2012No. Docket No. 14510-05Published

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

TIGERS EYE TRADING, LLC, SENTINEL ADVISORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Tigers Eye Trading, LLC v. Comm'r

Docket No. 14510-05.

United States Tax Court

138 T.C. 67; 2012 U.S. Tax Ct. LEXIS 6; 138 T.C. No. 6;

February 13, 2012, Filed

Tigers Eye Trading, LLC v. Commissioner, T.C. Memo 2009-121, 2009 Tax Ct. Memo LEXIS 118 (T.C., 2009)

An appropriate order will be issued, denying participating partner's motion to revise the stipulated decision.

The stipulated decision in this Son of BOSS TEFRA partnership-level case, entered by the Court Dec. 1,…

Also in this document: Dissent · Foley; Concurrence · Halpern; Concurrence · Wherry; Dissent · Marvel; Dissent · Holmes.

2Cases cited137 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. Agostini v. FeltonSupreme Court of the United States · 1997

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