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JT USA, LP v. C.I.R.

No. 12-70037.

771 F.3d 654 (2014)

JT USA, LP; JTR-LLC; Tax Matters Partner, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed November 14, 2014.

Attorney(s) appearing for the Case

Joan I. Oppenheimer (argued), Tamara W. Ashford , Deputy Assistant Attorney General, Teresa E. McLaughlin , Tax Division Department of Justice, Washington, DC, for Respondent-Appellant.

Richard V. Vermazen (argued), Law Office of Richard V. Vermazen, Ernest S. Ryder and Lauren A. Rinsky , Ernest S. Ryder & Associates, Inc., APLC, San Diego, CA, for Petitioners-Appellees.

Opinion by Judge Trott; Dissent by Judge Callahan.

OPINION

TROTT, Circuit Judge:

We review de novo the Tax Court's reading and application of a TEFRA statute1 in a convoluted action arising from (1) a partnership's attempted use of a bogus tax shelter to offset capital gains, and (2) the Commissioner of Internal Revenue's subsequent denial of a $32.5 million "loss" claimed by the partnership to eliminate income tax liability on an asset sale resulting in a $28 million capital...

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