Legal Opinion
AD Global Fund, LLC ex rel. North Hills Holding, Inc. v. United States
United States Court of Federal Claims
Decided September 16, 2005No. 04-336TPublishedCited by 16 opinions
1Opinion of the Court
OPINION
CHRISTINE O. C. MILLER, Judge.
This case is before the court on plaintiffs motion for summary judgment. Plaintiff asserts that the Internal Revenue Service failed to issue a Final Partnership Administrative Adjustment for plaintiffs 1999 tax return within the statutorily required time period prescribed by 26 U.S.C. (the “I.R.C.”) § 6229(a) (2000), thereby rendering plaintiffs partnership items “final” and barring the IRS from further action against plaintiff. Argument has been held, and the parties and amicus curiae filed supplemental briefs.
The issue to be resolved calls for…
2Cases cited74 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Marbury v. MadisonSupreme Court of the United States · 1803
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Exxon Mobil Corp. v. Allapattah Services, Inc.Supreme Court of the United States · 2005
- Cannon v. University of ChicagoSupreme Court of the United States · 1979
69 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Ad Global Fund, Llc, by and Through North Hills Holding, Inc., a Partner Other Than the Tax Matters Partner v. United StatesCourt of Appeals for the Federal Circuit · 2007
- Grapevine Imports, Ltd. v. United StatesUnited States Court of Federal Claims · 2007
- Clearmeadow Investments, LLC v. United StatesUnited States Court of Federal Claims · 2009
- Grapevine Imports, Ltd. v. United StatesUnited States Court of Federal Claims · 2006
11 more not listed; retrieve them via the Exa API.