NEW MILLENNIUM TRADING, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3439-06.

T.C. Memo. 2017-9

NEW MILLENNIUM TRADING, LLC, AJF-1, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 10, 2017.



MEMORANDUM FINDINGS OF FACT AND OPINION

Respondent issued a notice of final partnership administrative adjustment (FPAA) with respect to New Millennium Trading, LLC (NMT), for NMT's 1999 tax year. In the FPAA respondent determined, among other things,1 that NMT was a sham and should be disregarded...

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