Legal Opinion

Basr Partnership, by and Through, William F. Pettinati, Sr., Tax Matters Partner v. United States

United States Court of Federal Claims

Decided October 29, 2013No. 10-244PublishedCited by 9 opinions

1Opinion of the Court

REVISED MEMORANDUM OPINION AND FINAL ORDER

BRADEN, Judge.

This ease concerns a petition filed in the United States Court of Federal Claims, pursuant to 28 U.S.C. § 1508, for a readjustment and refund of federal taxes paid, plus interest. The pending motion for summary judgment requests that the court determine that the refund, plus interest, is due, because a January 20, 2010 Internal Revenue Service (“IRS”) Notice of Final Partnership Administrative Adjustment (“FPAA”) was time-barred by 26 U.S.C. § 6229(c)(1). In the alternative, the pending motion argues that the FPAA is timebarred, because…

2Cases cited32 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Lujan v. Defenders of WildlifeSupreme Court of the United States · 1992
  3. Scott v. HarrisSupreme Court of the United States · 2007
  4. Warth v. SeldinSupreme Court of the United States · 1975
  5. Friends of the Earth, Inc. v. Laidlaw Environmental Services (TOC), Inc.Supreme Court of the United States · 2000

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3Cited by9 opinions

  1. Basr Partnership v. United StatesCourt of Appeals for the Federal Circuit · 2015
  2. John Finnegan v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019
  3. Lawson Environmental Services, LLC v. United StatesUnited States Court of Federal Claims · 2016
  4. Basr Partnership v. United StatesCourt of Appeals for the Federal Circuit · 2019
  5. BASR Partnership Ex Rel. Pettinati v. United StatesUnited States Court of Federal Claims · 2017

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