Legal Opinion
Alpha I, L.P. v. United States
United States Court of Federal Claims
Decided November 25, 2008No. Nos. 06-407T, 06-408T, 06-409T, 06-410T, 06-411T, 06-810T, 06-811TPublishedCited by 12 opinions
1Opinion of the Court
*623 OPINION
HEWITT, Judge.
I. Background
Plaintiffs challenge “the readjustment of partnership items that were adjusted by the Internal Revenue Service [(IRS)] in a Notice of Final Partnership Administrative Adjustment [ (FPAA) ] issued to [plaintiffs] with respect to [plaintiffs’] Forms 1065 U.S. Return of Partnership Income for the tax years ended December 31, 2001 [ (tax year 2001) ] and December 31, 2002 [ (tax year 2002) ].” First Amended Complaint [of Alpha I, L.P.] for Readjustment of Partnership Items Under Code Section 6226 (Alpha Amended Complaint or Alpha Amended Compl.) 1. The IRS…
2Cases cited15 opinions
- Commissioner v. AckerSupreme Court of the United States · 1959
- 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
- Zirker v. CommissionerUnited States Tax Court · 1986
- McCrary v. CommissionerUnited States Tax Court · 1989
10 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Clearmeadow Investments, LLC v. United StatesUnited States Court of Federal Claims · 2009
- Alpha I, L.P. Ex Rel. Sands v. United StatesCourt of Appeals for the Federal Circuit · 2012
- Alpha I, L.P. v. United StatesUnited States Court of Federal Claims · 2010
- Alpha I, L.P. ex rel. Sands v. United StatesUnited States Court of Federal Claims · 2009
7 more not listed; retrieve them via the Exa API.