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SOUTHGATE MASTER FUND LLC v. UNITED STATES OF ...

caselaw.findlaw.com/us-5th-circuit/1581331.html

Sep 30, 2011 ... Case opinion for US 5th Circuit SOUTHGATE MASTER FUND LLC v. UNITED STATES OF AMERICA. Read the Court's full decision on ...

Southgate Master Fund LLC v. U.S. - Journal of Accountancy

www.journalofaccountancy.com/content/dam/jofa/archive/issues/2009/11/southgate.pdf

This case is a tax dispute between Plaintiff Southgate Master Fund, LLC. (“ Southgate”) and the ... Beal is Southgate's primary United States investor, and the .

Tax MVP: Dentons' Todd Welty - Law360

www.law360.com/articles/601828/tax-mvp-dentons-todd-welty

Dec 4, 2014 ... Securing Southgate Master Fund LLC a rare 97 percent concession from the IRS of nearly $300 million and first-chairing the Schaeffler Group's ...

IRS Wins Tax Shelter Trifecta - Forbes

www.forbes.com/sites/robertwood/2011/10/10/irs-wins-tax-shelter-trifecta/

Oct 10, 2011 ... Image via hendrick.com The Justice Department announced victories in three tax shelter cases at once: Southgate Master Fund LLC v. United ...

Tax Shelters: The Ninth Circuit Reverses a Grant of Summary ...

taxcontroversyposts.postschell.com/a-sham-partnership-case/

Aug 7, 2015 ... Id., slip op. at *2-*3 (reversing Broadwood Inv. Fund LLC v. ... Id., slip op. at *25, the case that it relied upon, Southgate Master Fund, LLC v.

December 2011 - PwC

www.pwc.com/us/en/tax-services-multinationals/newsletters/mergers-and-acquisitions/assets/pwc-this-month-ma-december-2011.pdf

Proposed regulations defining "interest in a limited partnership as a limited partner". Southgate Master Fund LLC v. United States: Fifth Circuit denies rehearing ...

Dallas' Richest Man Sues IRS for $200 Million | Dallas Observer

www.dallasobserver.com/news/dallas-richest-man-sues-irs-for-200-million-7135962

Jun 25, 2013 ... ... had established a sham partnership, Southgate Master Fund, LLC, ... intended to make profit when he formed Southgate Master Fund but ...

Current Developments in Partners and Partnerships - The Tax Adviser

www.thetaxadviser.com/issues/2012/feb/burton-feb12.html

Jan 31, 2012 ... The same issue arose in Home Concrete & Supply LLC. ..... Southgate Master Fund LLC's disposition of its portfolio of NPLs generated more ...

Broadwood Investment Fund LLC v. United States

taxprof.typepad.com/files/broadwood.pdf

Sep 21, 2012 ... Petitioners Broadwood Investment Fund LLC, Mosman Investment Fund LLC, Han Kook LLC. JS-6. O ..... Southgate Master Fund, L.L.C. v.

TaxProf Blog: TaxProf Blog

taxprof.typepad.com/taxprof_blog/new_cases/page/2/

Dec 1, 2014 ... [Broadwood Investment Fund LLC v. ...... The plaintiff, Southgate Master Fund, L.L.C., was formed for the purpose of facilitating the acquisition of ...

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Southgate Master Fund: The Sham Partnership Doctrine Gets Messy ...

taxblawg.net

Dec 13, 2011 ... Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United ...

Justice Department Prevails in Three Tax Shelter Cases on Same Day

www.justice.gov

Oct 4, 2011 ... In Southgate Master Fund LLC v. United States, the U.S. Court of Appeals for the Fifth Circuit, based in New Orleans, affirmed a lower court ...

Texas Billionaire Beal And Feds Reach Deal On DAD-dy Of All Tax ...

www.forbes.com

Apr 11, 2014 ... ... first case—a 2002 tax return filed by Southgate Master Fund LLC. ... penalties he'd paid for claiming Southgate's 2002 losses—the case that ...