Legal Opinion
3K Investment Partners, 3K Investments LLC, Tax Matters Partner v. Commissioner
United States Tax Court
Decided September 3, 2009No. 3891-06Unknown
1Opinion of the Court
133 T.C. No. 6
UNITED STATES TAX COURT 3K INVESTMENT PARTNERS, 3K INVESTMENTS LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3891-06. Filed September 3, 2009. In this partnership-level proceeding involving a so- called Son-of-BOSS transaction, P has moved to compel R to produce redacted copies of all tax opinions collected by R that have been issued regarding Son-of-BOSS transactions, as well as a list of the names and addresses of all law firms and accounting firms known to R to have issued tax opinion letters regarding Son-of-BOSS…
2Cases cited16 opinions
- Tax Analysts v. Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 1997
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Church of Scientology v. Internal Revenue ServiceSupreme Court of the United States · 1987
- Kligfeld Holdings v. Comm'rUnited States Tax Court · 2007
- United States of America and Ralph L. Guyette, Special Agent, Internal Revenue Service v. John B. HarringtonCourt of Appeals for the Second Circuit · 1968
11 more not listed; retrieve them via the Exa API.