BCP Trading and Investments, et al v. Cmsnr. IRS
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May 28, 2021
DC Circuit Won't Revisit Nix Of $3.1B In Losses Via Tax Sham
The D.C. Circuit won't reconsider its decision that affirmed the U.S. Tax Court and found a partnership couldn't claim $3.1 billion in losses generated through a tax sham, the appeals court said.
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May 21, 2021
DC Circ. Urged To Review Basis Adjustments In $3.1B Tax Row
The D.C. Circuit should reconsider affirming the U.S. Tax Court's basis adjustments in its decision disallowing a partnership's $3.1 billion in losses because those adjustments were erroneous and could result in incorrect liabilities, the entity said Friday.
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March 23, 2021
Partnership's $3.1B Loss Was Tax Sham, DC Circ. Affirms
The IRS' decision to disallow more than $3.1 billion in losses by a partnership was correctly affirmed by the U.S. Tax Court because the losses were generated through a tax sham, the D.C. Circuit said Tuesday.
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September 17, 2020
DC Circ. Told IRS Missed Window To Challenge $3.1B Loss
The U.S. Tax Court incorrectly decided there were valid statute of limitation extensions that permitted the Internal Revenue Service to disallow more than $3.1 billion in losses for a partnership's members, the members told the D.C. Circuit on Thursday.
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August 14, 2020
DC Circ. Told Partnership In $3.1B Loss Suit Not Tax Sham
The U.S. Tax Court wrongly decided that a partnership was a tax sham and disallowed more than $3.1 billion in losses for its members because the partnership served a legitimate business purpose, the members told the D.C. Circuit.
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June 29, 2020
Partnership's $3.1B Losses Rightly Nixed, DC Circ. Told
The U.S. Tax Court correctly found that a partnership was a sham intended to avoid taxes and properly disallowed over $3.1 billion in artificial losses for its members, the U.S. told the D.C. Circuit Monday.