Petaluma FX Partners, LLC v. Comm'r
United States Tax Court
P challenges adjustments in a final partnership administrative adjustment (FPAA) issued to a partnership (PFP). P stipulated most of the adjustments in the FPAA and argues that the Court lacks jurisdiction over the remaining determinations. P stipulated that he will not contest any determinations in the FPAA over which the Court finds it has jurisdiction except for the valuation penalties, which P argues do not apply to the partnership items at issue as a matter of law.
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P challenges adjustments in a final partnership administrative adjustment (FPAA) issued to a partnership (PFP). P stipulated most of the adjustments in the FPAA and argues that the Court lacks jurisdiction over the remaining determinations. P stipulated that he will not contest any determinations in the FPAA over which the Court finds it has jurisdiction except for the valuation penalties, which P argues do not apply to the partnership items at issue as a matter of law. R argues that all remaining determinations in the FPAA are partnership items or are otherwise within the Court's…
1Opinion of the Court
OPINION
Goeke, Judge:
This case is before the Court on the parties’ cross-motions for summary judgment under Rule 121.1 The issues for decision are: (1) Whether the Court has jurisdiction in this partnership-level proceeding to determine whether Petaluma PX Partners, L.L.C. (Petaluma), should be disregarded for tax purposes; (2) whether the Court has jurisdiction to determine whether the partners’ outside bases in Petaluma were greater than zero; (3) whether the Court has jurisdiction to determine whether the accuracy-related penalties determined in a notice of final partnership administrative…
2Cases cited32 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
27 more not listed; retrieve them via the Exa API.
3Cited by79 opinions
- New Millennium Trading, L.L.C. v. Comm'rUnited States Tax Court · 2008
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2010
- 106 Ltd. v. Comm'rUnited States Tax Court · 2011
- BLAK Invs. v. Comm'rUnited States Tax Court · 2009
74 more not listed; retrieve them via the Exa API.