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PETALUMA FX PARTNERS, LLC v. C.I.R.

No. 08-1356.

591 F.3d 649 (2010)

PETALUMA FX PARTNERS, LLC and Ronald Scott Vanderbeek, a Partner Other Than The Tax Matters Partner, Appellants v. COMMISSIONER OF INTERNAL REVENUE Service, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided January 12, 2010.

Attorney(s) appearing for the Case

Edward M. Robbins Jr. argued the cause and filed the briefs for appellants.

Sheldon M. Kay, Thomas A. Cullinan, and Julie P. Bowling were on the brief for amicus curiae AJF-1, LLC in support of appellants.

Joan I. Oppenheimer, Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief were Gilbert S. Rothenberg, Acting Deputy Assistant Attorney General, and Richard Farber, Supervisory Attorney. Judith A. Hagley, Attorney, entered an appearance.

Opinion for the Court filed by Chief Judge SENTELLE.

SENTELLE, Chief Judge:

Petaluma FX Partners, LLC appeals from the Tax Court's decision that it had jurisdiction over several partnership-level determinations and that valuation misstatement penalties applied. Specifically, the Tax Court held that it had jurisdiction to determine that Petaluma was a sham, lacked economic substance, and should be disregarded for tax purposes; that Petaluma's partners had no outside basis in...

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