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Nov 2, 2010 ... THE UNITED STATES OF AMERICA ... Sugarloaf Fund LLC and Jetstream Business Limited, states as .... See e.g., Southgate Master Fund v.

From Coltec and “You Know it When You See It” - Steptoe ...


Southgate Master Fund LLC et al. v. ... 13 and the frequent inclusion of economic substance v. United States, No. ... 14 See, e.g., America's Affordable Health Choices Act of 2009, H.R. 3200, 111th Cong.; ... 2009-251; Southgate Master Fund v.

UCLA-2010-Net-Worth-Requirements.docx - US Tax Disputes


This discussion contains excerpts from Southgate Master Fund, LLC v. United States, 651 .... v. UNITED STATES of America, Defendant-Appellant. No. 94-1192 .

Economic Substance : Miller & Chevalier's Tax Appellate Blog


Aug 30, 2012 ... Citing Southgate Master Fund, L.L.C. v. United States, 659 F.3d 466, 484 (5th Cir. ... United States, 459 F.3d 220 (2d Cir. ... East Hall was completed in 1929, hosted the Miss America Pageant for many years, and is listed on ...

T.C. Memo. 2015-28 UNITED STATES TAX COURT ... - U.S. Tax Court


Feb 18, 2015 ... ce=gbs_ge_summary_r&cad=0#v=onepage&q&f=false. ... antebellum America pilots earned a “princely salary.” See id. at 34. Nowadays a ...... remanding 136 T.C. 1 (2011); Southgate Master Fund, L.L.C. ex rel. Montgomery.

Belmont Investments LLC v. United States, Case No. 4 ... - Tax Trials


Aug 2, 2010 ... IN THE UNITED STATES DISTRICT COURT. FOR THE EASTERN DISTRICT OF TEXAS. SHERMAN DIVISION. BEMONT INVESTMENTS, LLC., by and .... capital that might be needed to fund the takeover. ..... as required by Chevron U.S.A. Inc. v. ... cannot be applied retroactively); Maguire Partners-Master.

Tax Analysts -- Defining 'Partnership' for Federal Tax Purposes


May 12, 2011 ... In its 1949 decision in Commissioner v. ...... Southgate Master Fund LLC v. United States is an example.<sup>87</sup> The case involves the transfer of ...

Daniel Charest Partner - Burns Charest LLPBurns Charest LLP


His work has taken place across the United States: federal and state courts from coast to coast with ... Prodagio Holdings LLC v. ... Southgate Master Fund v.

The “Meaningful Stake” Debate: Third Circuit Reverses Tax Court ...


Jan 31, 2013 ... On August 27, 2012, the United States Court of Appeals for the Third Circuit ... of the United States Tax Court in the case of Historic Boardwalk Hall, LLC v. ... of the Fourth Circuit in Virginia Historic Tax Credit Fund 2001, LP v. ... on the boardwalk in Atlantic City, hosted the annual Miss America Pageant.

Robbins, Russell, Englert, Orseck, Untereiner & Sauber LLP | Mark T ...


He has argued five cases before the Supreme Court of the United States, briefed many ... Advised major investment fund on constitutional and administrative-law ...

Helpful Resources

Southgate Master Fund LLC v. United States - U.S. Court of Appeals ...


Sep 30, 2011 ... v. UNITED STATES OF AMERICA,. Defendant–Appellee–Cross- ... plaintiff, Southgate Master Fund, L.L.C., was formed for the purpose of.

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


Dec 13, 2011 ... Southgate Master Fund: The Sham Partnership Doctrine Gets Messy ... Southgate Master Fund, LLC v United States, No, 09-11166 at 27 (Sep.

Nevada Partners Fund LLC v. United States - 600 Camp


Jun 24, 2013 ... v. UNITED STATES OF AMERICA, by and through its agent, the Internal. Revenue Service ...... Southgate Master Fund, LLC ex rel. Montgomery ...

Southgate Masters Fund v. United States


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

Broadwood Investment Fund LLC v. United States


Sep 21, 2012 ... LLC et al.,. Plaintiffs, vs. UNITED STATES OF AMERICA,. Defendant. ..... Southgate Master Fund, L.L.C. v. United States, 659 F.3d 466,. 468-69 ...