Legal Opinion
Uviado, LLC ex rel. Khan v. United States ex rel. Internal Revenue Service
District Court, S.D. Texas
Decided August 2, 2010No. Civil Action Nos. H-09-0052, H-09-0065PublishedCited by 1 opinion
1Opinion of the Court
MEMORANDUM AND OPINION
LEE H. ROSENTHAL, District Judge.
In January 2009, two investment partnerships, Uviado, LLC and Leman, LLC, filed these lawsuits against the United States, seeking readjustment of partnership items proposed in two notices of Final Partnership Administrative Adjustment (“FPAA”) issued in August 2008 by the Commissioner of the Internal Revenue Service. The issue addressed in this opinion is venue, which turns on the partnerships’ principal place of business.
The plaintiffs contend that in late 2008, they moved the principal place of their business to Houston, Texas. The…
2Cases cited20 opinions
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- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Commissioner v. SolimanSupreme Court of the United States · 1993
- Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
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3Cited by1 opinion
- Uviado, LLC Ex Rel. Khan v. US Ex Rel. IrsDistrict Court, S.D. Texas · 2010