United States Ninth Circuit

In a dispute arising from an IRS investigation into a "Son-of-BOSS” scheme and its subsequent determination that petitioner's short foreign currency transactions were shams, judgment of the tax court granting summary judgment in favor of the IRS is affirmed where the IRS properly sent petitioner an affected item notice of deficiency because the deficiency required a partner-level determination, and because the tax court had jurisdiction to redetermine affected items in a deficiency notice that relied on the IRS' determination that petitioner's trading was a sham.

Appellate Information

• Decided 08/23/2011
• Published 08/23/2011

Judges

• NOONAN

Court

• United States Ninth Circuit

Counsel

• For Appellant:
  
• Edward Robbins, Joan Oppenheimer