28 U.S.C. § 1509
No jurisdiction in cases involving refunds of tax shelter promoter and understatement penalties
The United States Court of Federal Claims shall not have jurisdiction to hear any action or proceeding for any refund or credit of any penalty imposed under section 6700 of the Internal Revenue Code of 1986 (relating to penalty for promoting abusive tax shelters, etc.) or section 6701 of such Code (relating to penalties for aiding and abetting understatement of tax liability).
Notes of Decisions
Cited in 1
case (1 in the last 5 years), 2025–2025 · leading case: AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC
AJ Ruiz Consultoria Empresarial S.A. v. Colorado Investment Holdings, LLC (2025)
“23 That law firm may have 22 28 U.S.C. § 1509 (b): If the court grants recognition under section 1517, and subject to any limitations that the court may impose consistent with the policy of this chapter— (1) the foreign representative has the capacity to sue and be sued in a…”
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