In a partnership-taxation case involving Marriott, United States Court of Federal Claims' grant of summary judgment in favor of the government is affirmed in its determination that in 1994 the obligation to close a short sale qualified as a liability under I.R.C. section 753 and that the IRS properly adjusted the outside basis of the Marriott partners for the 1994 tax year to account for the partnership's assumption of the obligation to close certain short sales.
Appeal from: United States Court of Federal Claims
Decided October 28, 2009
Per Curium Opinion
For Appellant: Robert L. Willmore, Crowell & Moring LLP, Washington, DC
For Appellee: Joan I. Oppenheimer, Appellate Section, Tax Division, United States Department of Justice, Washington, DC.