Legal Opinion

Bemont Investments, L.L.C. Ex Rel. Tax Matters Partner v. United States

Court of Appeals for the Fifth Circuit

Decided April 26, 2012No. 10-41132PublishedCited by 28 opinions

1Opinion of the Court

W. EUGENE DAVIS, Circuit Judge:

These consolidated cases sought judicial review of notices of final partnership administrative adjustment (FPAA) issued to Bemont Investments, L.L.C. (Bemont) and BPB Investments, L.C. (BPB). Following that review in the district court, the government appeals two aspects of the district court’s judgment: (1) the ruling on the partnerships’ motion for partial summary judgment disallowing the 40% valuation misstatement penalty, and (2) the ruling post trial holding that the FPAA issued to Bemont for the 2001 tax year was time-barred. The partnerships appeal the…

2Cases cited6 opinions

  1. David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
  2. Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  3. Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
  4. Streber v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
  5. Darlene Swayze v. United States of America, Stuart Martin v. United StatesCourt of Appeals for the Ninth Circuit · 1986

1 more not listed; retrieve them via the Exa API.

3Cited by28 opinions

  1. United States v. WoodsSupreme Court of the United States · 2013
  2. Thomas Montgomery v. IRSCourt of Appeals for the D.C. Circuit · 2022
  3. William E. Gustashaw, Jr. v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
  4. NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014
  5. Alpha I, L.P. Ex Rel. Sands v. United StatesCourt of Appeals for the Federal Circuit · 2012

23 more not listed; retrieve them via the Exa API.

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