A Reputation For-Integrity And Excellence

A Reputation For-Integrity And Excellence

Fidelity International v. US

On Behalf of | Oct 21, 2020 | Administrative Law

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.