Legal Opinion
Petaluma FX Partners, LLC v. Commissioner of IRS
Court of Appeals for the D.C. Circuit
Decided June 26, 2015No. 12-1364PublishedCited by 11 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SRINIVASAN.
SRINIVASAN, Circuit Judge:
This case comes before this court for a third time. It arises out of the Tax Court’s determination that Petaluma FX Partners, LLC, was a sham entity and so would be disregarded for tax purposes, resulting in the potential imposition of penalties against individual partners for underreporting their taxable income. The issue we now consider concerns whether the Tax Court had jurisdiction at the current, partnership-level stage to determine the applicability of the penalties to the individual partners, or whether…
2Cases cited13 opinions
- Lashawn A. v. Marion S. Barry, Jr.Court of Appeals for the D.C. Circuit · 1996
- United States v. WoodsSupreme Court of the United States · 2013
- American Radio Relay League, Inc. v. Federal Communications CommissionCourt of Appeals for the D.C. Circuit · 2008
- Yesudian Ex Rel. United States v. Howard UniversityCourt of Appeals for the D.C. Circuit · 2001
- James Sherley v. Kathleen SebeliusCourt of Appeals for the D.C. Circuit · 2012
8 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Ronald Calzone v. Donald SummersCourt of Appeals for the Eighth Circuit · 2019
- Mellow Partners, A Partnership v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2018
- Jeff Blau, Tax Matters Partner of RERI Holdings I, LLC v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2019
- Highpoint Tower Technology Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2019
- BCP Trading and Investments, LLC v. Cmsnr. IRSCourt of Appeals for the D.C. Circuit · 2021
6 more not listed; retrieve them via the Exa API.