Legal Opinion
Russian Recovery Fund Ltd. v. United States
United States Court of Federal Claims
Decided May 19, 2008No. Nos. 06-31T, 06-36TPublishedCited by 12 opinions
1Opinion of the Court
OPINION
BRUGGINK, Judge.
Pending is plaintiff Russian Recovery Fund Limited’s motion for summary judgment for the 2001 tax year. Russian Recovery Fund Limited (“RRF”), a partnership, brings this “Complaint for Readjustment of Partnership Items” pursuant to 26 U.S.C. § 6226(f) (1986). RRF asserts that the Final Partnership Administrative Adjustment (“FPAA”) issued by the Internal Revenue Service (“IRS”) for the 2001 tax year improperly adjusted an individual partner-level item in a partnership-level proceeding. Defendant has not cross-moved because it alleges that it needs discovery to respond…
2Cases cited14 opinions
- N.C.F. Energy Partners v. CommissionerUnited States Tax Court · 1987
- Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
- Ad Global Fund, Llc, by and Through North Hills Holding, Inc., a Partner Other Than the Tax Matters Partner v. United StatesCourt of Appeals for the Federal Circuit · 2007
- Hambrose Leasing 1984-5 Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
- Chomp Assoc. v. CommissionerUnited States Tax Court · 1988
9 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- 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 · 2008
- Russian Recovery Fund Ltd. v. United StatesUnited States Court of Federal Claims · 2011
- Alpha I, L.P. v. United StatesUnited States Court of Federal Claims · 2008
7 more not listed; retrieve them via the Exa API.