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Southgate Master Fund LLC v. United States - Fifth Circuit Court of ...

www.ca5.uscourts.gov/opinions\pub\09/09-11166-CV0.wpd.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: 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.

In the Supreme Court of the United States - US Department of Justice

www.justice.gov/sites/default/files/osg/briefs/2015/12/18/15-331_tifd_iii-e_opp_.pdf

Dec 18, 2015 ... TIFD III-E, LLC, PETITIONER v. UNITED STATES OF AMERICA. ON PETITION FOR A WRIT .... Southgate Master Fund, L.L.C. v. United States,.

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.

Third Circuit Reverses Tax Court, Clarifies Scope of Economic ...

www.crowell.com/NewsEvents/AlertsNewsletters/all/Third-Circuit-Reverses-Tax-Court-Clarifies-Scope-of-Economic-Substance-Doctrine-in-Historic-Boardwalk-Hall-LLC-v-Commissioner

Sep 11, 2012 ... The Tax Court held for the taxpayer, finding that the LLC had a legitimate ... Commissioner, and Southgate Master Fund v. United States.

Broadwood Investment Fund LLC v. United States

taxprof.typepad.com/files/broadwood.pdf

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 ...

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

www.steptoe.com/assets/attachments/4112.pdf

Under section 956, a CFC's “investment in United States property” is treated as a deemed dividend to .... Southgate Master Fund LLC et al. v. United States; No.

Flow-Through Entity Structuring Issues in Today's Climate - Steptoe ...

www.steptoe.com/attachment.html/4010/TEI_FlowThroughEntityStructuringIssues_2010.pdf

Mar 9, 2010 ... Health Care for America Act” (the “House Health. Care Reform Bill”) (H.R. 3962), ..... •Southgate Master Fund, LLC v. United States, No. ... LLC v. United States, 104 AFTR 2d 2009-6666 (7th Cir. 2009). Taxpayer Victories.

in the united states district court - Captive Insurance Companies

www.captiveinsurancecompanies.com/cases/saltybrine/168_Plaintiffs_Post_Trial_Brief_18apr13.pdf

Apr 18, 2013 ... UNITED STATES OF AMERICA, .... ii. TABLE OF AUTHORITIES. Federal Cases. Allison v. United States, 80 .... Southgate Master Fund, LLC v.

Economic Substance : Miller & Chevalier's Tax Appellate Blog

appellatetax.com/category/economic-substance/

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 ...

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

www.journalofaccountancy.com

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

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 ...

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN ...

www.justice.gov

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