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 US 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 an industry expert 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 defenses."