Sep 30, 2011 ... plaintiff, Southgate Master Fund, L.L.C., was formed for the purpose of ... A
partnership for tax purposes, Southgate's disposition of its portfolio.
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 ...
Aug 26, 2013 ... Petaluma FX Partners, LLC v. Commissioner, 591 F.3d. 649, 651 (D.C. Cir. 2010)
; see also Southgate Master Fund,. L.L.C. v. United States ...
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
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.
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 ...
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 ...
Proposed regulations defining "interest in a limited partnership as a limited
partner". Southgate Master Fund LLC v. United States: Fifth Circuit denies
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 ...
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 ...