Russian Recovery Fund Ltd. v. United States

OPINION

BRUGGINK, Judge.

This Tax Equity and Fiscal Responsibility Act (“TEFRA”), 26 U.S.C. §§ 6221-6233 (2006), action is a petition for readjustment of partnership items brought under 26 U.S.C. § 6226(a)2 by Russian Recovery Advisors, LLC (“RRA”) as the tax matters partner for Russian Recovery Fund, LTD (“RRF”). Plaintiffs allege, among other contentions, that the Internal Revenue Service’s (“IRS”) issuance of a Final Partnership Administrative Adjustment (“FPAA”) for the tax year ending December 31, 2000, was untimely and therefore invalid, and that the representative partners’ 2000 and 2001…