Sugarloaf Fund, LLC v. CIR

In the United States Court of Appeals For the Seventh Circuit ____________________ No. 19‐2468 SUGARLOAF FUND, LLC and JETSTREAM BUSINESS LIMITED, Petitioners‐Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent‐Appellee. ____________________ Appeal from the United States Tax Court. No. 30410‐12 No. 15857‐13 No. 15858‐13 No. 165‐14 No. 28657‐14 ____________________ ARGUED FEBRUARY 14, 2020 — DECIDED MARCH 6, 2020 ____________________ Before RIPPLE, SYKES, and SCUDDER, Circuit Judges. SCUDDER, Circuit Judge. Before us for a third time is a tax shelter designed by attorney John Rogers…