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Indu Rawat v. Cmsnr. IRS

Docket 23-1142, U.S. Court of Appeals, D.C. Circuit (June 5, 2023)
Petitioner - Appellant Indu Rawat
Respondent - Appellee Commissioner of Internal Revenue
Cmsnr. Irs
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Board of Directors of the San Diego Association of Governments, acting as the San...

Docket 1:21-cv-04893, New York Southern District Court (June 2, 2021)
Judge Jesse M. Furman, presiding
Anti-Trust
DivisionFoley Square
FlagsCLOSED, ECF, MEMBER, RELATED
Demand$9,999,000
Cause15:1 Antitrust Litigation (Monopolizing Trade)
Case Type410 Anti-Trust
Tags410 Anti-Trust, 410 Anti-Trust
Plaintiff Board of Directors of the San Diego Association of Governments, acting as the San Diego County Regional Transportation Commission
Defendant Bank of America Corporation
Defendant Bank of America, N.A.
...
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Demetrius Crump, et al. v. Appellate Division of Superior Court of Los Angeles Coun...

Docket B307744, California State Court of Appeals, Second District (Sept. 28, 2020)
Division8
Case TypeCR
Petitioner Demetrius Crump, et al.
Respondent Appellate Division of Superior Court of Los Angeles County
Real Party in Interest The People
...
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Opinion

Document Indu Rawat v. Cmsnr. IRS, 23-1142 (D.C. Cir. Jul. 23, 2024)
When a nonresident alien sells an interest in a U.S. partnership, a straightforward sourcing rule has governed since the enactment of the Tax Cuts and Jobs Act of 2017 (TCJA), Pub. L. No. 115- 97, 131 Stat. 2054: income from the sale is U.S.-source (and hence taxable).
While Rawat eventually paid the requested amount (plus penalties, interest, and other adjustments), she promptly petitioned the Tax Court for a refund, contending that the inventory gain was foreign- source income and therefore nontaxable.
Section 751(a) states: The amount of any money, or the fair market value of any property, received by a transferor partner in exchange for all or a part of his interest in the partnership attributable to—
There had arisen, however, a practice of partners using that rule to skirt ordinary-income taxes they otherwise would owe by disposing of their partnership interests before realizing income, in an effort to obtain more favorable capital-gains treatment.
The Report later states: “The statutory treatment proposed, in general, regards the income rights [from § 751(a) property] as severable from the partnership interest and as subject to the same tax consequences which would be accorded an individual entrepreneur.” Id. at 71.
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Ellis et al. v. Hurley et al.

Docket B300769, California State Court of Appeals, Second District (Sept. 12, 2019)

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Ellis et al. v. Hurley et al.

Docket B300806, California State Court of Appeals, Second District (Sept. 12, 2019)

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Securities and Exchange Commission v. Mark Loman

Docket 2:19-cv-06187, California Central District Court (July 18, 2019)
Judge Michael W. Fitzgerald, presiding, Magistrate Judge Alicia G. Rosenberg
Securities, Commodities, Exchange

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USA v. Cai et al

Docket 2:19-cr-00145, California Central District Court (March 8, 2019)
Judge John A. Kronstadt, presiding.

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