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  5. 161 T.C. No. 11
 

YA GLOBAL INVESTMENTS, LP v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 14546-15, 28751-15.

161 T.C. No. 11

YA GLOBAL INVESTMENTS, LP f.k.a. CORNELL CAPITAL PARTNERS, LP, YORKVILLE ADVISORS, GP LLC, TAX MATTERS PARTNER AND YA GLOBAL INVESTMENTS, LP f.k.a. CORNELL CAPITAL PARTNERS, LP, YORKVILLE ADVISORS, LLC, TAX MATTERS PARTNER, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. YA GLOBAL INVESTMENTS, LP, YORKVILLE ADVISORS GP, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 15, 2023.

Attorney(s) appearing for the Case

Ellis L. Reemer , Henry C. Cheng , Tamara L. Shepard , and Caryn G. Schechtman , for petitioners.

Gretchen A. Kindel , Robert T. Bennett , Rebecca J. Kalmus , Charles E. Buxbaum , Shawna A. Early , Kelly M. Davidson , and Travis Vance III , for respondent.

OPINION

In these cases, we review notices of final partnership administrative adjustment (FPAAs) in which respondent adjusted various partnership items reported by YA Global Investments, LP, a limited partnership (YA Global or the partnership) for the taxable years ended December 31, 2006, 2007, 2008, and 2009.

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