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Southgate Master Fund LLC v. United States - US Department of ...

www.justice.gov/tax/Southgate_opinion.pdf

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.

CA 7 8/26/2013

media.ca7.uscourts.gov/cgi-bin/rssExec.pl?Submit=Display&Path=Y2013/D08-26/C:12-3367:J:Posner:aut:T:fnOp:N:1192659:S:0

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 ...

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

www.forbes.com/sites/janetnovack/2014/04/11/texas-billionaire-beal-and-feds-reach-deal-on-dad-dy-of-all-tax-refunds/

Apr 11, 2014 ... ... Beal's first case—a 2002 tax return filed by Southgate Master Fund LLC. In their decision, the judges nixed Beal's attempt to claim $1.1 billion ...

Southgate Master Fund v. United States - Robbins, Russell, Englert ...

www.robbinsrussell.com/sites/default/files/appellate_pdf/southgate-master-fund-v.-united-states-reply.pdf

SOUTHGATE MASTER FUND, L.L.C., by and through Montgomery Capital. Advisors, LLC its Tax Matters Partner,. Plaintiff-Appellant Cross-Appellee, v. UNITED ...

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 ...

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 ...

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 ...

Litigation/Controversy | Tax Law Roundup

www.taxlawroundup.com/litigationcontroversy/

In the first case, Southgate Master Fund LLC v. United States, the Fifth Circuit Court of Appeals, affirmed a lower court ruling that a purported “partnership” was …

Economic Substance | Tax Law Roundup

www.taxlawroundup.com/economic-substance/

In the first case, Southgate Master Fund LLC v. United States, the Fifth Circuit Court of Appeals, affirmed a lower court ruling that a purported “partnership” was …

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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 ...

IRS Wins Tax Shelter Trifecta - Forbes

www.forbes.com

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 ...

Southgate Masters Fund v. United States

taxprof.typepad.com

Aug 18, 2009 ... This case is a tax dispute between Plaintiff Southgate Master Fund, LLC. (“ Southgate”) and the United States of America (the “Government”).