Legal Opinion
Jade Trading, LLC v. United States
United States Court of Federal Claims
Decided April 29, 2011No. 03-2164TPublishedCited by 7 opinions
1Opinion of the Court
OPINION AND ORDER FOLLOWING REMAND
WILLIAMS, Judge.
This tax case comes before the Court on remand from the United States Court of Appeals for the Federal Circuit for a determination of whether this Court possesses jurisdiction to apply accuracy-related penalties in this partnership proceeding. In Jade Trading, LLC v. United States, 80 Fed.Cl. 11 (2007) (“Jade Trading I ”), this Court found that a variation of a bond and options sales strategy (“Son of BOSS”) transaction lacked economic substance and that accuracy-related penalties applied at the partnership level.
On appeal, the Federal Circuit…
2Cases cited10 opinions
- McNutt v. General Motors Acceptance Corp.Supreme Court of the United States · 1936
- Karen S. Reynolds v. Army and Air Force Exchange ServiceCourt of Appeals for the Federal Circuit · 1988
- Stephenson v. United StatesUnited States Court of Federal Claims · 2003
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Arbitrage Trading, Llc v. United StatesUnited States Court of Federal Claims · 2013
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Tigers Eye Trading, LLC, Sentinel Advisors, LLC, Tax Matters Partner v. CommissionerUnited States Tax Court · 2012
2 more not listed; retrieve them via the Exa API.