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PETALUMA FX PARTNERS, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 24717-05.

135 T.C. 581 (2010)

PETALUMA FX PARTNERS, LLC, RONALD SCOTT VANDERBEEK, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 15, 2010.

Attorney(s) appearing for the Case

Edward M. Robbins, Jr. , for petitioner.

Gerald A. Thorpe and Jason M. Kuratnick , for respondent.

SUPPLEMENTAL OPINION

GOEKE, Judge.

This matter is before the Court on remand from the Court of Appeals for the District of Columbia Circuit for further proceedings consistent with its opinion in Petaluma FX Partners, LLC v. Commissioner, 591 F.3d 649 (D.C. Cir. 2010), affg. in part, revg. in part, and vacating in part 131 T.C. 84 (2008). The issue for decision on remand is whether this Court has jurisdiction...

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