· 8/26/2013
Superior Trading, LLC v. Commissioner
Citations
- 728 F.3d 676
- 2013 WL 4505155
- 112 A.F.T.R.2d (RIA) 5936
- 2013 U.S. App. LEXIS 17814
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- finding the presumption triggered where the partner received a substantial distribution 10 months after contributing distressed receivables
- finding no joint business goal where one partner aimed to extract value from a worthless asset, and the other aimed to make the loss from that asset a “tax bonanza”
- finding no joint business goal where one partner aimed to extract value from a worthless asset, and the other aimed to make the loss from that asset a \tax bonanza\
- no joint business goal where one partner aimed to extract value on a worthless asset, and the other aimed to make the loss of that asset a \tax bonanza\
- applying the tests of Culbertson and Tower
- applying the tests of Culbertson and Tower
Source: CourtListener parenthetical corpus (CC0).
Judges: Easterbrook, Posner, Williams
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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