Montierth v. Deutsche Bank Nat'l Trust Co.

How courts have described this case

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

• holding that the United States Court of Federal Claims did not have jurisdiction to adjudicate a taxpayer refund claim under TEFRA, because whether the Internal Revenue Service (“IRS”
• holding that the United States Court of Federal Claims did not have jurisdiction to adjudicate a taxpayer refund claim under TEFRA, because whether the Internal Revenue Service (“IRS”
• acknowledging that “[e]ourts directly dealing with the sham transaction doctrine have concluded that its application presents a partnership item.”
• “[C]ourts directly dealing with the sham transaction doctrine have concluded that its application presents a partnership item.”
• “[Under section 6231(b)(1(C),] only those partnership items actually resolved in a settlement agreement are converted to nonpartnership items.”

Source: CourtListener parenthetical corpus (CC0).