Investments, LKF X Capital Corporation, Tax Matters Partner v. The Commissioner
of Internal Revenue
Analysis Group client the Internal Revenue Service was granted
summary judgment in U.S. Tax Court in LKF X Investments, LKF X Capital
Corporation, Tax Matters Partner v. The Commissioner of Internal Revenue.
At issue in the matter was the use of certain currency options by the
petitioner, the above-named LKF entities, to offset a tax obligation. The
Analysis Group team, led by Managing Principals Gaurav
Jetley and R.
Jeffrey Malinak, supported our academic affiliate and industry expert Thomas
Murphy in assessing the business purpose of the currency transactions. In
granting the IRS summary judgment, the Court concluded that "there is no genuine
issue as to any material fact regarding potential partnership-level
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