Legal Opinion
Mellow Partners, A Partnership v. Cmsnr. IRS
Court of Appeals for the D.C. Circuit
Decided May 22, 2018No. 16-1454PublishedCited by 20 opinions
1Opinion of the Court
Edwards, Senior Circuit Judge:
Mellow Partners ("Mellow"), a general partnership formed by and between two single-member LLCs, appeals the Tax Court's decisions holding that it had jurisdiction over partnership-related determinations concerning Mellow's partnership return for the 1999 tax year and imposing penalties for the underpayment of taxes. The Internal Revenue Service ("IRS") determined that Mellow was "formed and availed of solely for purposes of tax avoidance" and "constitute[d] an economic sham." Final Partnership Administrative Adjustment Letter, Tax Year Ended: December 31, 1999,…
2Cases cited29 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Auer v. RobbinsSupreme Court of the United States · 1997
- Thomas Jefferson University v. ShalalaSupreme Court of the United States · 1994
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
24 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Jeff Blau, Tax Matters Partner of RERI Holdings I, LLC v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2019
- Tingzi Wang v. U.S. Citizenship & Immigration Servs.Court of Appeals for the D.C. Circuit · 2019
- San Diego Gas & Elec. Co. v. Fed. Energy Regulatory Comm'nCourt of Appeals for the D.C. Circuit · 2019
- Grecian Magnesite Mining, Indus. & Shipping Co. v. Comm'r of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2019
- Sagarwala v. CissnaCourt of Appeals for the D.C. Circuit · 2019
15 more not listed; retrieve them via the Exa API.