Legal Opinion
BLAK Investments, Kyle W. Manroe Trust, Robert and Lori Manroe, Trustees, Tax Matters Partner v. Commissioner
United States Tax Court
Decided December 23, 2009No. Docket 1283-07UnknownCited by 1 opinion
1Opinion of the Court
OPINION
Haines, Judge:
This case is before the Court on respondent’s motion and petitioner’s cross-motion for partial summary judgment filed pursuant to Rule 121.1 The issues are: (1) Whether the effective date of section 6707A precludes application of section 6501(c)(10) to the transaction at issue; (2) whether the transaction at issue is a listed transaction; and (3) whether the period of limitations for assessment of tax resulting from the adjustment of partnership items with respect to the transaction at issue is open for 2001 under section 6501(c)(10).
Background
BLAK Investments (the…
2Cases cited19 opinions
- United States v. MenascheSupreme Court of the United States · 1955
- Harisiades v. ShaughnessySupreme Court of the United States · 1951
- Crane v. CommissionerSupreme Court of the United States · 1947
- E. I. Dupont De Nemours & Co. v. DavisSupreme Court of the United States · 1924
- United States v. Olympic Radio & Television, Inc.Supreme Court of the United States · 1955
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3Cited by1 opinion
- David B. Greenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2021