United States Federal Circuit

In a partnership-taxation case involving Marriott, United States Court of Federal Claims' grant of summary judgment in favor of the government is affirmed in its determination that in 1994 the obligation to close a short sale qualified as a liability under I.R.C. section 753 and that the IRS properly adjusted the outside basis of the Marriott partners for the 1994 tax year to account for the partnership's assumption of the obligation to close certain short sales.

Appellate Information

• Decided 10/28/2009
• Published 10/28/2009

Judges

Court

• United States Federal Circuit

Counsel