NPR INVESTMENTS, L.L.C., by and through Nelson Roach, a Partner other than the Tax Matters Partner, Plaintiff-Appellee Cross-Appellant,
Harold W. Nix; Charles C. Patterson, Intervenor Plaintiffs-Appellees,
v.
United States of America, Defendant-Appellant Cross-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
January 23, 2014.
January 23, 2014.
Attorney(s) appearing for the Case
Thomas A. Cullinan (argued), Sutherland Asbill & Brennan, L.L.P., Atlanta, GA, J. Hoke Peacock, II, Esq. , Orgain, Bell & Tucker, L.L.P., Beaumont, TX, for Plaintiff-Appellee Cross-Appellant, Intervener Plaintiffs-Appellees.
In a Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA")1 partnership proceeding, the district court held that valuation misstatement and substantial understatement tax penalties were inapplicable to NPR Investments, LLC (NPR). The United States appeals those determinations. The district court also held that a notice of a Final Partnership Administrative Adjustment (FPAA) issued by the Internal...
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