Legal Opinion
Fidelity International Currency Advisor a Fund, LLC v. United States
District Court, D. Massachusetts
Decided October 18, 2010No. Civil 05-40151-FDS, 06-40130-FDS, 06-40243-FDS, 06-40244-FDSPublishedCited by 22 opinions
1Opinion of the Court
AMENDED [CORRECTED] FINDINGS OF FACT AND CONCLUSIONS OF LAW
SAYLOR, District Judge.
This is a dispute concerning two complex tax shelter transactions. The plaintiffs in these consolidated actions are Fidelity International Currency Advisor A Fund, LLC and Fidelity High Tech Advisor A Fund, LLC. The tax matters partner, and the principal taxpayer who invested in and benefltted from the tax shelter transactions at issue, was Richard J. Egan. 1
Richard Egan was one of the founders of EMC Corporation and the former ambassador to Ireland. He entered into the tax shelter transactions to avoid large…
2Cases cited60 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Knetsch v. United StatesSupreme Court of the United States · 1960
55 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Fidelity International Currency Advisor a Fund, LLC Ex Rel. Tax Matters Partner v. United StatesCourt of Appeals for the First Circuit · 2011
- Johnson v. Proskauer Rose LLPAppellate Division of the Supreme Court of the State of New York · 2015
- NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014
- Thompson v. CommissionerUnited States Tax Court · 2011
17 more not listed; retrieve them via the Exa API.