United States First Circuit
Fidelity International v. US, 10-2421
In an appeal from a judgment of the district court upholding certain adjustments to plaintiff's partnership returns and a 40 percent penalty for tax underpayment by the IRS, 26 U.S.C. section 6226(a), judgment is affirmed because certain option transactions used to shield income were correctly disallowed losses where the transactions lacked economic substance.
Appellate Information
- Decided 10/21/2011
- Published 10/21/2011
Judges
- BOUDIN
Court
- United States First Circuit