United States Federal Circuit

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Rusian Recovery Fund Ltd. v. US, 2016-1718

In a suit seeking readjustment of partnership items pursuant to the Tax Equity and Fiscal Responsibility Act (TEFRA), I.R.C. sections 6221-6233 (2000), alleging that the Internal Revenue Service's (IRS) October 14, 2005 Notice of Final Partnership Administrative Adjustment (2005 FPAA) improperly disallowed approximately $50 million of losses that plaintiff had claimed for fiscal year 2000 and imposed a 40% penalty on any underpayment, the Court of Federal Claims' judgment that the limitations period for assessing taxes against plaintiff's indirect partners had expired as to some, but not all, indirect partners, and subsequent judgment in favor of the government are affirmed where there are no reversible errors in the Court of Federal Claims rulings.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/03/13




  • United States Federal Circuit


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