Legal Opinion
Fidelity International Currency Advisor a Fund, LLC Ex Rel. Tax Matters Partner v. United States
Court of Appeals for the First Circuit
Decided October 21, 2011No. 10-2421PublishedCited by 30 opinions
1Opinion of the Court
BOUDIN, Circuit Judge.
Fidelity International Currency Advisor A Fund (“Fidelity”) seeks review of a district court judgment resolving a controversy between Fidelity and the Internal Revenue Service (“IRS”). In substance, the district court sustained IRS adjustments to Fidelity’s partnership returns for the two tax years at issue and upheld a 40 percent penalty for tax underpayment. Fid. Int’l Currency Advisor A Fund, LLC v. United States, 747 F.Supp.2d 49 (D.Mass.2010).
The litigation arises out of the following events. Richard Egan was the founder of EMC Corporation, a manufacturer of…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
10 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Superior Trading, LLC v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
- William E. Gustashaw, Jr. v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2012
- Kerman v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
- Alpha I, L.P. Ex Rel. Sands v. United StatesCourt of Appeals for the Federal Circuit · 2012
25 more not listed; retrieve them via the Exa API.