Legal Opinion
Sugarloaf Fund, LLC v. Comm'r
Court of Appeals for the Seventh Circuit
Decided December 21, 2018No. 18-1046PublishedCited by 7 opinions
1Opinion of the Court
Scudder, Circuit Judge.
Before us in this appeal is a tax shelter almost identical to the one we agreed reflected an abusive sham in Superior Trading, LLC v. Commissioner , 728 F.3d 676 (7th Cir. 2013). We reach the same conclusion here and affirm the Tax Court's judgment and imposition of penalties.
I
A
John Rogers is an experienced tax lawyer and the architect of a tax structure that the Commissioner of Internal Revenue has found to be an abusive tax-avoidance scheme. In Superior Trading , we considered the legitimacy of the scheme Rogers designed and implemented for the 2003 tax year. Here we…
2Cases cited7 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
- Asa Investerings Partnership,appellants v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 2000
- Superior Trading, LLC v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- McDonald Restaurants of Illinois, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1982
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Sugarloaf Fund, LLC v. CIRCourt of Appeals for the Seventh Circuit · 2020
- Frances Rogers v. CIRCourt of Appeals for the Seventh Circuit · 2021
- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2019
- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2019
- Samuel Wegbreit & Elizabeth J. Wegbreit v. CommissionerUnited States Tax Court · 2019
2 more not listed; retrieve them via the Exa API.