Sugarloaf Fund LLC v. Comm'r
United States Tax Court
In 2005, S, a purported partnership, set up Illinois common law business trusts Main Trust and Sub-Trust. S then transferred distressed Brazilian consumer receivables to Main Trust. S, Main Trust, and the trustee in turn allocated the receivables to Sub-Trust. E transferred cash to Main Trust in exchange for the entire beneficial interest in Sub-Trust.
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In 2005, S, a purported partnership, set up Illinois common law business trusts Main Trust and Sub-Trust. S then transferred distressed Brazilian consumer receivables to Main Trust. S, Main Trust, and the trustee in turn allocated the receivables to Sub-Trust. E transferred cash to Main Trust in exchange for the entire beneficial interest in Sub-Trust. E wrote off most of the value of the receivables as an I.R.C. sec. 166 bad debt deduction, claiming a carryover basis in the receivables equal to S' basis. R issued a notice of final partnership administrative adjustment regarding S' 2004 and…
1Opinion of the Court
SUGARLOAF FUND LLC, JETSTREAM BUSINESS LIMITED, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sugarloaf Fund LLC v. Comm'r
Docket No. 671-10.
United States Tax Court
141 T.C. 214; 2013 U.S. Tax Ct. LEXIS 24; 141 T.C. No. 4;
September 5, 2013, Filed
Superior Trading, LLC v. Comm'r, 137 T.C. 70, 2011 U.S. Tax Ct. LEXIS 38 (2011)
An appropriate order will be issued.
In 2005, S, a purported partnership, set up Illinois common law business trusts Main Trust and Sub-Trust. S then transferred distressed Brazilian consumer receivables to Main Trust. S, Main Trust, and the…
2Cases cited9 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Elizabeth N. Callaway v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
- Superior Trading, LLC v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- Cemco Investors, LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2008
- PCMG Trading Ptnrs. XX, L.P. v. Comm'rUnited States Tax Court · 2008
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