Ad Global Fund, Llc, by and Through North Hills Holding, Inc., a Partner Other Than the Tax Matters Partner v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding the TEFRA scheme “intends that adjustments to a partnership tax return be completed in one consistent proceeding before individual partners are assessed for partnership items”
• “Section 6501 explicitly provides that it applies to any tax imposed by the title, which would include tax imposed for partnership items. No exception is provided for assessment of taxes for partnership items.” (citation and footnote omitted)
• “Section 6501 simply cross-references § 6229(a) as an ‘extension’ of period for partnership items.”
• “The ‘first step “is to determine whether the language at issue has a plain and unambiguous meaning with regard to the particular dispute in the case.”’” (quoting Barnhart v. Sigmon Coal Co., Inc., 534 U.S. at 450 (quoting Robinson v. Shell Oil Co., 519 U.S. at 340))

Source: CourtListener parenthetical corpus (CC0).