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BCP TRADING v. COMMISSIONER OF INTERNAL REVENUE

No. 19-1068, Consolidated with 19-1072, 19-1098, 19-1099, 19-1122, 19-1123.

991 F.3d 1253 (2021)

BCP TRADING AND INVESTMENTS, LLC, et al., Appellants v. COMMISSIONER OF INTERNAL REVENUE, Appellee Virginia Simpson, Appellant.

United States Court of Appeals, District of Columbia Circuit.

Decided March 23, 2021.

Attorney(s) appearing for the Case

Jeremy C. Marwell , Washington, DC, argued the cause for appellants Kalkhoven-Pettit Partnerships. George M. Clarke III argued the cause for appellants Esrey-LeMay Partnerships. With them on the briefs were Mireille R. Oldak , Vivek A. Patel , Washington, DC, Robert E. McKenzie , Kathleen M. Lach , Chicago, IL, Matthew X. Etchemendy , Washington, DC, Michael L. Charlson , San Francisco, CA, and David C. Cole .

Virginia Simpson, pro se, filed the brief for appellant Virginia Simpson.

Jennifer M. Rubin , Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was Joan I. Oppenheimer , Attorney.

Before: Srinivasan, Chief Judge, Henderson and Walker, Circuit Judges.

In January 2008, the Commissioner of the Internal Revenue Service (Commissioner) issued tax adjustments to the partnership of BCP Trading & Investments, LLC (BCP) for tax years 2000 and 2001. Members of BCP—themselves limited partnerships—challenged the adjustments, arguing they were untimely...

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