Legal Opinion
Petaluma FX Partners, LLC v. Commissioner of Internal Revenue Service
Court of Appeals for the D.C. Circuit
Decided January 12, 2010No. 08-1356PublishedCited by 78 opinions
1Opinion of the Court
Opinion for the Court filed by Chief Judge SENTELLE.
SENTELLE, Chief Judge:
Petaluma FX Partners, LLC appeals from the Tax Court’s decision that it had jurisdiction over several partnership-level determinations and that valuation misstatement penalties applied. Specifically, the Tax Court held that it had jurisdiction to determine that Petaluma was a sham, lacked economic substance, and should be disregarded for tax purposes; that Petalu ma’s partners had no outside basis in the disregarded partnership; and that the gross valuation misstatement penalty applied. Petaluma FX Partners, LLC v.…
2Cases cited7 opinions
- Asa Investerings Partnership,appellants v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 2000
- Andantech L.L.C. v. CommissionerCourt of Appeals for the D.C. Circuit · 2003
- Keener v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Desmet v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2009
- American Boat Co., LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2009
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3Cited by78 opinions
- United States v. WoodsSupreme Court of the United States · 2013
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Jade Trading, LLC Ex Rel. Ervin v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Superior Trading, LLC v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- 106 Ltd. v. Commissioner, IRSCourt of Appeals for the D.C. Circuit · 2012
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