AD GLOBAL FUND, LLC, by and through NORTH HILLS HOLDING, INC., a Partner Other Than the Tax Matters Partner, v. THE UNITED STATES
(04-336T)
Pleading and practice; motion to certify for interlocutory appeal under 28 U.S.C. § 1291(d)(2) (2000); Tax Equity and Fiscal Responsibility Act of 1982, 26 U.S.C. § § 6221-6234 (2000); 26 U.S.C. § § 6501(a), 6229(a) (2000); prescribed period within which adjustment to partnership tax return must be issued; canons of construction for statutory interpretation applicable to tax statutes; plain meaning; legislative history; presumptions relating to tax legislation
Signed by Judge Miller, C..