Salty Brine 1, Ltd, et al. v. United States, No. 13-10799 (5th Cir. 2014)
Annotate this CaseThe Commissioner issued a Notice of Final Partnership Administrative Adjustment to TKOP for the 2006 tax year. TKOP deposited the amount required by 26 U.S.C. 6226(e) with the IRS and then commenced this action seeking readjustment of partnership items, which was consolidated with seven lawsuits. On appeal, TKOP challenged the district court's determination that the transfer of certain overriding royalty interests through a complicated transaction was an invalid attempt to assign income. The court affirmed the judgment, concluding that the record amply supported this finding and supported the district court's conclusion that the income was taxable to TKOP for the 2006 tax year.
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