1. Home
  2. Browse Decisions
  3. Memo.
  4. T.C. Memo.
  5. T.C. Memo. 2017-151
 

BCP TRADING AND INVESTMENTS, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 10200-08, 10201-08.

T.C. Memo. 2017-151

BCP TRADING AND INVESTMENTS, LLC, WILLIAM T. ESREY TRADING PARTNERS, LP, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 7, 2017.

Attorney(s) appearing for the Case

Robert H. Albaral , David G. Glickman , George M. Clarke, III , and Mireille R. Oldak , for petitioner.

George M. Gerachis , Michael L. Charlson , David C. Cole , and Juliana D. Hunter , for intervenor Kalkhoven/Pettit Trading Partners, LP, tax matters partner.1

Robert E. McKenzie and Kathleen M. Lach , for PCMG Trading Partners VI, LP, a partner other than the tax matters partner.

Roy Wulf , Ewan D. Purkiss , Mary E. Wynne , Kevin G. Croke , L. Katrine Shelton , and Henry C. Bonney, Jr. , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

These cases are about a purported partnership that used almost perfectly offsetting bets on foreign currency to pass over $3.3 billion of tax losses through to its partners—partners who contributed only $16.5 million. These massive losses were passed through to some very wealthy...

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