Court of Federal Claims Lacks Jurisdiction over Partner’s Outside Basis

In what may very well be the last decision of many rendered to the plaintiff’s in Jade Trading, LLC, the Court of Federal Claims, on remand from the Court of Appeals for the Federal Circuit, determined that under the Tax Equity and Fiscal Responsibility Act (TEFRA) it did not have jurisdiction to impose penalties on partners which relied on the partner’s outside basis.

Read the opinion here:
Jade Trading, LLC v. United States, No. 03-2164T (Fed. Cl. April 29, 2011)

Fed. Circuit: Taxpayer Failed to Certify WOTC and WtW Credits

The Court of Appeals for the Federal Circuit affirms the Court of Federal Claims grant of summary judgment in favor of the United States ruling that the taxpayer failed to meet the necessary certification requirements to be eligible for the Work Opportunity Tax Credit (WOTC) and Welfare to Work (WtW) tax credit.

Read the Opinion:
Manor Care v. U.S., No. 2010-5038 (Jan. 21, 2011)