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.
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Jade Trading, LLC v. United States, No. 03-2164T (Fed. Cl. April 29, 2011)
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.
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Manor Care v. U.S., No. 2010-5038 (Jan. 21, 2011)
The Court of Federal Claims uphold accuracy related penalties against several Son of Boss tax shelter partnerships.
Murfam Farms v. United States, Docket Nos. 06-245T, 06-246T, and 06-247T (Fed. Claims August 16, 2010)
The Court of Federal Claims imposed penalties on tax shelter participants.
Alpha I, L.P. v. United States, Docket 06-407T (Fed. Cl. May 27, 2010)