In Uncategorized on 11/12/2013 at 15:23

Thanksgiving came early for The Great Dissenter, Judge Mark V. Holmes, as Eighth Circuit, in the concurring opinion of Chief Judge Riley, exalts Judge Holmes’ great dissent in Randall J. & Karen G. Thompson, 137 T. C. 17, filed 12/27/11. See my blogpost “The Great Dissenter”, 12/28/11.

Chief Judge Riley, concurring: “I find myself in fundamental agreement with both of my colleagues in this complex case. As emphasized by Judge Wollman (and comprehensively explained in Judge Holmes’ dissenting Tax Court opinion), the partnership-level determination that Randall Thompson’s outside basis was overstated still requires partner-level computation and legal analysis to determine Thompson’s correct tax liability.” Randall J. Thompson; Karen G. Thompson v. Commissioner of Internal Revenue, No 12-1725, decided 9/9/13.

So Judge Wherry’s 36-page expatiation anent FPAA and partnership-level adjustments goes down; See Randall J. & Karen G. Thompson, Docket No. 30586-98, filed 11//12/13.

He may not know the partitive genitive, but Judge Holmes sure knows tax law.


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