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CHAI v. C.I.R.

Docket Nos. 15-1653 (L); 15-2414 (XAP) August Term, 2016.

851 F.3d 190 (2017)

Jason CHAI, Petitioner-Appellant-Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee-Cross-Appellant.

United States Court of Appeals, Second Circuit.

Decided: March 20, 2017.

Attorney(s) appearing for the Case

JEREMY KLAUSNER ( Frank Agostino , Lawrence M. Brody , on the brief), Agostino & Associates, P.C., Hackensack, NJ, for Petitioner-Appellant-Cross-Appellee.

ARTHUR T. CATTERALL , Attorney, Tax Division, Department of Justice ( Richard Farber , on the brief), for Catherine D. Ciraolo , Acting Assistant Attorney General, Washington, D.C., for Respondent-Appellee-Cross-Appellant.

Before: Katzmann, Chief Judge, Wesley and Carney, Circuit Judges.

Taxpayer Jason Chai's appeal and the Commissioner of Internal Revenue's (the "Commissioner") cross-appeal relate to Chai's underreporting of income in his 2003 tax return, principally in connection with a $2 million payment Chai received from Delta Currency Trading, LLC ("Delta") for his role in a now-defunct tax-shelter scheme...

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