Legal Opinion
Klamath Strategic Investment Fund, LLC v. United States
District Court, E.D. Texas
Decided January 31, 2007No. 1:04-cv-00278PublishedCited by 32 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
WARD, District Judge.
Pursuant to Fed.R.Civ.P. 52, the court issues the following memorandum opinion and order, which constitutes the court’s findings of fact and conclusions of law. 1
1. Introduction.
This case involves a tax shelter known as Bond Linked Issue Premium Structure (“BLIPS”). It is a civil action by the plaintiffs against the United States under 26 U.S.C. § 6226 for readjustment of partnership items. The court holds that the loan transactions at issue must be disregarded for federal income tax purposes. The court further holds that the taxpayers are not…
2Cases cited17 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- David E. Heasley and Kathleen Heasley v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
12 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- American Boat Co., LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2009
- New Millennium Trading, L.L.C. v. Comm'rUnited States Tax Court · 2008
27 more not listed; retrieve them via the Exa API.