IN THE DISTRICT COURT OF THE VIRGIN ISLANDS 
DIVISION OF ST. THOMAS AND ST. JOHN 
 
 
V.I. DERIVATIVES, LLC, BY VIFX, LLC, 
: 
Its TAX MATTERS PARTNER, by   
  
: 
CIVIL ACTION  
RICHARD G. VENTO, its TAX MATTERS  
: 
PARTNER 
 
 
 
 
 
: 
NO. 06-04 
 
 
 
 
 
 
 
: 
 
 
 
v. 
 
 
 
: 
 
 
 
 
 
 
 
: 
DIRECTOR, VIRGIN ISLANDS BUREAU OF 
: 
INTERNAL REVENUE 
 
 
 
: 
______________________________________________________________________________ 
VIFX, LLC, by RICHARD G. VENTO, its  
: 
TAX MATTERS PARTNER  
 
 
: 
CIVIL ACTION 
 
 
 
 
 
 
 
: 
 
 
 
v. 
 
 
 
: 
NO. 06-05 
 
 
 
 
 
 
 
: 
DIRECTOR, VIRGIN ISLANDS BUREAU OF  
: 
INTERNAL REVENUE 
 
 
 
: 
 
 
 
ORDER 
 
 
AND NOW, this 29th day of September, 2022, upon consideration of Respondent, Virgin 
Islands Bureau of Internal Revenue's Motions for Summary Judgment (Document Nos. 163 and 
164) and the Respondents' Responses in Opposition thereto, it is hereby ORDERED that the 
Motions are GRANTED for the reasons outlined in the accompanying Memorandum, the 
determinations made by the Virgin Islands Bureau of Internal Revenue in the FPAAs issued to 
V.I. Derivatives, LLC and VIFX, LLC for the tax year ended December 31, 2001 are SUSTAINED 
IN FULL, and FINAL JUDGMENT is entered as a matter of law in favor of the Virgin Islands 
Bureau of Internal Revenue and against the Petitioners on the merits of the MLD transaction and  
as to the penalties imposed.  
 
Case: 3:06-cv-00004-JRS-RM   Document #: 186   Filed: 09/30/22   Page 1 of 2
 
 
 
 
 
 
 
 
BY THE COURT: 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
/s/ Juan R. Sánchez 
 
 
 
 
 
 
 
 
______________________ 
 
 
 
 
 
 
 
 
Juan R. Sánchez,        J.     
Case: 3:06-cv-00004-JRS-RM   Document #: 186   Filed: 09/30/22   Page 2 of 2