Petaluma FX Partners, LLC v. Commissioner of Internal Revenue Service

How courts have described this case

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

• noting that nothing about the concept of outside basis indicates that it is more appropriately determined at the partnership level
• noting that nothing about the concept of outside basis indicates that it is more appropriately determined at the partnership level
• noting that nothing about the concept of outside basis indicates that it is more appropriately determined at the partnership level
• finding itself “unable to uphold” the penalty determinations in a Tax Court partnership proceeding where the penalties could not be computed without a separate partner-level proceeding
• finding itself \unable to uphold\ the penalty determinations in a Tax Court partnership proceeding where the penalties could not be computed without a separate partner-level proceeding
• finding itself “unable to uphold” the penalty determinations in a Tax Court partnership proceeding where the penalties could not be computed without a separate partner-level proceeding

Source: CourtListener parenthetical corpus (CC0).