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FIDELITY INTERN. CURRENCY ADVISOR A FUND v. U.S.

No. 10-2421.

661 F.3d 667 (2011)

FIDELITY INTERNATIONAL CURRENCY ADVISOR A FUND, LLC, by the TAX MATTERS PARTNER, Plaintiff, Appellant, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided October 21, 2011.

Attorney(s) appearing for the Case

William F. Nelson with whom Ronald L. Buch, Jr. , David J. Curtin , Kiara L. Rankin and Bingham McCutchen LLP were on brief for appellant.

Judith A. Hagley , Tax Division, Department of Justice, with whom Richard Farber , Tax Division, Department of Justice, Gilbert S. Rothenberg , Acting Deputy Assistant Attorney General, and Carmen M. Ortiz , United States Attorney, were on brief for appellee.

Before TORRUELLA, BOUDIN and THOMPSON, Circuit Judges.

BOUDIN, Circuit Judge.

Fidelity International Currency Advisor A Fund ("Fidelity") seeks review of a district court judgment resolving a controversy between Fidelity and the Internal Revenue Service ("IRS"). In substance, the district court sustained IRS adjustments to Fidelity's partnership returns for the two tax years at issue and upheld a 40 percent penalty for tax underpayment. Fid. Int'l Currency Advisor A Fund, LLC v. United States,

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