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

No. 12-1364.

792 F.3d 72 (2015)

PETALUMA FX PARTNERS, LLC, Ronald Scott Vanderbeek, A Partner other than the Tax Matters Partner, Appellee. v. COMMISSIONER OF INTERNAL REVENUE Service, Appellant.

United States Court of Appeals, District of Columbia Circuit.

Decided June 26, 2015.

Attorney(s) appearing for the Case

Joan I. Oppenheimer , Attorney, U.S. Department of Justice, argued the cause for appellant. With her on the briefs were Tamara W. Ashford , Principal Deputy Assistant Attorney General, and Gilbert S. Rothenberg , Attorney. Andrew Weiner , Attorney, entered an appearance.

Edward M. Robbins Jr . argued the cause and filed the brief for appellee.

Opinion for the Court filed by Circuit Judge SRINIVASAN.

This case comes before this court for a third time. It arises out of the Tax Court's determination that Petaluma FX Partners, LLC, was a sham entity and so would be disregarded for tax purposes, resulting in the potential imposition of penalties against individual partners for underreporting their taxable income. The issue...

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