1. Home
  2. Browse Decisions
  3. T.C.
  4. 131 T.C.
  5. 131 T.C. No. 18
 

NEW MILLENNIUM TRADING, L.L.C. v. COMMISSIONER OF INTERNAL REVENUE

No. 3439-06.

131 T.C. No. 18

NEW MILLENNIUM TRADING, L.L.C., AJF-1, L.L.C., TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States tax Court.

Filed December 22, 2008.

Attorney(s) appearing for the Case

Thomas A. Cullinan and Julie P. Bowling, for petitioner.

James R. Rich, for respondent.

OPINION

GOEKE, Judge.

This case is before the Court on petitioner's motion for partial summary judgment filed pursuant to Rule 121.1 Petitioner asks that we hold section 301.6221-1T(c) and (d), Temporary Proced. & Admin. Regs., 64 Fed. Reg. 3838 (Jan. 26, 1999), invalid, or if valid, inapplicable. For the reasons stated herein, we will deny petitioner's motion in both respects.

Background

The following information...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases