IRS Never Proved Forex Trades Were Rigged, DC Circ. Hears

Law360 (October 23, 2019, 7:08 PM EDT) -- A U.S. Tax Court decision that a partnership should be denied $141 million in tax losses for engaging in sham foreign currency transactions should be reversed because the IRS never proved the trades were rigged, the D.C. Circuit heard Wednesday.

The Internal Revenue Service's argument that Endeavor Partners Fund LLC engaged in rigged deals to generate artificial losses for tax purposes was incomplete because the agency declined to call on five witnesses at trial who were supposed to substantiate its case, Adrienne Koch of Katsky Korins LLP, who represents Endeavor, said during oral arguments. Those witnesses could have proved that the foreign currency...

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