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KENNA TRADING, LLC, JETSTREAM BUSINESS LIMITED, TAX. MATTERS PARTNER, ET AL., Petitioners v. 1. COMMISSIONER OF INTERNAL REVENUE, Respondent. Docket Nos. 7551-08, 7552-08,. Filed October 16, 2014. 7553-08, 7554-08,. 7555-08, 7556-08,. 7618-08, 7625-08,. 9021-08, 9035-08,. 9036-08 ...
Aug 11, 2017 ... In his deposition in a related Tax Court case, Kenna Trading,. LLC v. Commissioner, 143 T.C. 322 (2014), Mr. Hartigan testified that Mr. Rogers directed him to make the $52,500 payment directly to Multiered. Investment LLC ( Multiered), a Brazilian company that had a business relationship with Mr. Rogers ...
Jan 6, 2017 ... 28657-14, 165-14, 15858-13, 15857-13, 30410-12. Further, in Kenna Trading,. LLC v. Commissioner, 143 T.C. 322, 327 (2014), petitioner was described as the. "central individual" in the case. For another decided case involving petitioner, see . Superior Trading, LLC v. Commissioner, 728 F.3d 676 (7th Cir.
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Skills. Trading Systems; Order Management; Hedge Funds; Electronic Trading; Equities; SQL; Business Analysis; Product Management; Bloomberg; Fixed Income; Microsoft SQL Server; Databases; XML; C#; Trading; Equity Trading; Agile Methodologies; Derivatives. How's this translation? Great; •; Has errors. Thanks for ...
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which the Service challenged taxpayer transactions under the economic substance doctrine. Kenna Trading, LLC. In 2014, in Kenna Trading, LLC,2 certain Brazilian retailers contributed distressed consumer accounts receivable to a limited liability company (LLC). The. LLC claimed a carryover tax basis in the receivables.