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

www.justice.gov/tax/Southgate_opinion.pdf

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 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., ... Advisors, LLC its Tax Matters Partner, ... v. UNITED STATES OF AMERICA,. Defendant-Appellee Cross-Appellant.

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

taxblawg.net/2011/12/13/southgate-master-fund-the-sham-partnership-doctrine-gets-messy-or-does-it/

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.

IRS Wins Tax Shelter Trifecta - Forbes

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

Oct 10, 2011 ... The Justice Department announced victories in three tax shelter cases at once: Southgate Master Fund LLC v. United States, Pritired 1 LLC v.

In the Supreme Court of the United States

www.chamberlitigation.com/sites/default/files/scotus/files/Reply Brief -- U.S. v. Woods, et al. (U.S. Supreme Court).pdf

UNITED STATES OF AMERICA, PETITIONER v. GARY WOODS, AS TAX MATTERS ... Arbitrage Trading, LLC v. United .... 1 See Southgate Master Fund, LLC v.

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 ... sense, Welty reduced his client's exposure in United States v.

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 …

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

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

Aug 7, 2015 ... United States, 2015 U.S. App. LEXIS 13501 (9th Cir. Aug. ... Id., slip op. at *2-*3 ( reversing Broadwood Inv. Fund LLC v. ... had economic substance, Id., slip op. at *25, the case that it relied upon, Southgate Master Fund, LLC v.

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 …

COMMITTEE ON SALES, EXCHANGES, AND BASIS - American Bar ...

www.americanbar.org/content/dam/aba/events/taxation/taxiq-fall11-jensen-sebnon1031.pdf

Oct 22, 2011 ... concern raised by the ABA Tax Section and the New York State Tax ..... See also Southgate Master Fund,. L.L.C. v. United States, 2011 TNT ...

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United States Court of Appeals

media.ca7.uscourts.gov

Aug 26, 2013 ... 2010); see also Southgate Master Fund,. L.L.C. v. United States, 659 F.3d 466, 469 ... tax loophole closed by the American Jobs Creation Act of.

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”).

Broadwood Investment Fund LLC v. United States

taxprof.typepad.com

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 ...