SEARCH

Tifd Iii-E, Inc v. United States of America

Thank you for sharing!

Your article was successfully shared with the contacts you provided.

Argued: May 16, 2011

Before: LEVAL, CABRANES, SACK, Circuit Judges.

16 The United States appeals from a judgment of the United States District Court for the 17 District of Connecticut (Underhill, J.) invalidating two notices of Final Partnership 18 Administrative Adjustments issued by the Internal Revenue Service. The district court so ruled 19 because it concluded that the taxpayer-plaintiff’s characterization of two tax-exempt Dutch 20 banks as its partners in Castle Harbour LLC was proper under Internal Revenue Code 21 § 704(e)(1). The district court also concluded that, even if the banks did not qualify as partners 22 under § 704(e)(1), the government was not entitled to impose a penalty pursuant to Internal 23 Revenue Code § 6662. The Court of Appeals (Leval, J.) holds that the evidence compels the 24 conclusion that the banks do not qualify as partners under § 704(e)(1), and that the government 25 is entitled to impose a penalty on the taxpayer for substantial understatement of income. The 26 judgment of the district court is REVERSED.

More From ALM

Premium Subscription

With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now

Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now

Bundle Subscriptions

Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now

From Data to Decisions

Dynamically explore and compare data on law firms, companies, individual lawyers, and industry trends.

Exclusive Depth and Reach.

Law.com Compass includes access to our exclusive industry reports, combining the unmatched expertise of our analyst team with ALM’s deep bench of proprietary information to provide insights that can’t be found anywhere else.

Big Pictures and Fine Details

Law.com Compass delivers you the full scope of information, from the rankings of the Am Law 200 and NLJ 500 to intricate details and comparisons of firms’ financials, staffing, clients, news and events.

New Jersey Legal Awards 2024

October 29, 2024
East Brunswick, NJ

New Jersey Law Journal honors lawyers leaving a mark on the legal community in New Jersey with their dedication to the profession.

Learn More

GlobeSt. Women of Influence (WOI) 2024

July 22, 2024 - July 24, 2024
Lake Tahoe, CA

GlobeSt. Women of Influence Conference celebrates the women who drive the commercial real estate industry forward.

Learn More

New York Legal Awards 2024

September 05, 2024
New York, NY

The New York Law Journal honors attorneys and judges who have made a remarkable difference in the legal profession in New York.

Learn More

Paralegal/Legal Assistant

Eichen Crutchlow Zaslow LLP is a highly regarded legal firm based in Edison, New Jersey. The firm specializes in medical malpractice and per...

Apply Now ›

Associate Professor or Professor of Law

The George Washington University Law School invites applications for multiple tenure-track or tenured faculty appointments, at the rank of A...

Apply Now ›

Employment Attorneys Senior Counsel - Los Angeles, Ventura, California

Gordon Rees Scully Mansukhani has an immediate opening for experienced Employment Attorneys in its Los Angeles and Ventura offices. Candida...

Apply Now ›

Lawyers of Distinction

06/27/2024
The American Lawyer

Professional Announcement

View Announcement ›

06/21/2024
Daily Business Review

Full Page Announcement

View Announcement ›

Blume Forte Fried Zerres & Molinari

06/14/2024
New Jersey Law Journal

Professional Announcement

View Announcement ›