Legal Opinion

Npr Investments, LLC, Ex Rel. Roach v. United States

District Court, E.D. Texas

Decided August 10, 2010No. 4:05-cv-00219PublishedCited by 2 opinions

1Opinion of the Court

MEMORANDUM OPINION AND ORDER

T. JOHN WARD, District Judge.

This case is a Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) partnership proceeding under Section 6226 of the Internal Revenue Code. 1 Plaintiff NPR Investments, LLC (“NPR”) filed this lawsuit seeking readjustment of certain items determined in the Internal Revenue Service’s Notice of Final Partnership Administrative Adjustment (FPAA) pursuant to 26 U.S.C. § 6226. The Court held a bench trial from March 8 to March 10, 2010. The parties submitted post-trial briefs on the issues raised in the bench trial. The Court issues the…

2Cases cited17 opinions

  1. United States v. BoyleSupreme Court of the United States · 1985
  2. Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
  3. David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
  4. Riland v. CommissionerUnited States Tax Court · 1982
  5. Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009

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3Cited by2 opinions

  1. NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014
  2. Nix v. United StatesDistrict Court, E.D. Texas · 2018

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