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SOROBAN CAPITAL PARTNERS LP v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 16217-22, 16218-22.

161 T.C. No. 12

SOROBAN CAPITAL PARTNERS LP, SOROBAN CAPITAL PARTNERS GP LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 28, 2023.

Attorney(s) appearing for the Case

Elizabeth J. Smith, Kathleen S. Gregor, Caitlyn M. Leonard, and Armando Gomez, for petitioner.

Emerald G. Smith, Naseem Jehan Khan, Michael E. Washburn, and Jonathan E. Cornwell, for respondent.

OPINION

Soroban Capital Partners LP (Soroban) is a limited partnership composed of a general partner and limited partners. For 2016 and 2017 (years in issue), Soroban was subject to the TEFRA1 unified audit and litigation procedures of sections 6221-62342 as then in...

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