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OMEGA FOREX GROUP, LC BY AND THROUGH FLATH v. U.S.

No. 17-4066.

906 F.3d 1196 (2018)

OMEGA FOREX GROUP, LC, BY AND THROUGH Robert K. FLATH, a Partner other than a Tax Matters Partner, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Tenth Circuit.

October 22, 2018.

Attorney(s) appearing for the Case

Michael D. Black ( April M. Medley , with him on the briefs), Parr Brown Gee & Loveless, P.C., Salt Lake City, Utah, appearing for Appellant.

Anthony T. Sheehan , Attorney, Tax Division ( Richard E. Zuckerman , Principal Deputy Attorney General, Travis A. Greaves , Deputy Assistant Attorney General, Gilbert S. Rothenberg and Bruce R. Ellisen , Attorneys, Tax Division, with him on the brief), United States Department of Justice, Washington, DC, appearing for Appellee.

Before BRISCOE, BALDOCK, and EID, Circuit Judges.

Plaintiff Omega Forex Group LC (Omega), appearing by and through partner Robert Flath (Flath), appeals from the district court's decision affirming two Notices of Final Partnership Administrative Adjustment (FPAA) issued by the Internal Revenue Service to Omega. The two FPAAs, on the basis of fraud at the partnership level...

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