Legal Opinion

Palm Canyon X Invs., LLC v. Comm'r

United States Tax Court

Decided December 15, 2009No. 5610-06UnpublishedCited by 1 opinion

PC, a single-member LLC owned by AHI, entered into offsetting market-linked deposit contracts with SG. Each contract provided for potential premium interest on the deposit; the terms of the potential premium interest in each contract constituted a European-style foreign currency digital option. Shortly thereafter, CFA became a member in PC.

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PC, a single-member LLC owned by AHI, entered into offsetting market-linked deposit contracts with SG. Each contract provided for potential premium interest on the deposit; the terms of the potential premium interest in each contract constituted a European-style foreign currency digital option. Shortly thereafter, CFA became a member in PC. As a result, PC was classified as a partnership for tax purposes, and the offsetting MLD options were treated as contributions to the newly formed partnership. AHI claimed a basis in its PC partnership interest that included the premium it owed for the…

1Opinion of the Court

PALM CANYON X INVESTMENTS, LLC, AH INVESTMENT HOLDINGS, INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Palm Canyon X Invs., LLC v. Comm'r

No. 5610-06

United States Tax Court

T.C. Memo 2009-288; 2009 Tax Ct. Memo LEXIS 292; 98 T.C.M. (CCH) 574;

December 15, 2009, Filed

PC, a single-member LLC owned by AHI, entered into offsetting market-linked deposit contracts with SG. Each contract provided for potential premium interest on the deposit; the terms of the potential premium interest in each contract constituted a European-style foreign currency digital option.…

2Cases cited51 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  4. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  5. Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000

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3Cited by1 opinion

  1. NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014

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