Legal Opinion

Clearmeadow Investments, LLC v. United States

United States Court of Federal Claims

Decided June 24, 2009No. 05-1223 TPublishedCited by 21 opinions

1Opinion of the Court

OPINION

ALLEGRA, Judge:

“When pondering sexy legal issues,” one commentator recently noted, “it is doubtful that tax law crosses the minds of many.”1 Yet, once in a while (alright, a long while), a tax dispute bursts into the mainstream. Take, for example, the legal controversy swirling around the so-called “Son of BOSS” transactions — the quoted phrase being short for “sales option bond strategy,” the legatee of the “bond and option sales” or “BOSS” strategy. While this case involves a Son of BOSS transaction, perhaps it is best to start by examining the earlier BOSS strategy— “qualis pater…

2Cases cited108 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
  4. United States v. Diebold, Inc.Supreme Court of the United States · 1962
  5. Gregory v. HelveringSupreme Court of the United States · 1935

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3Cited by21 opinions

  1. American Boat Co., LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2009
  2. Fidelity International Currency Advisor a Fund, LLC Ex Rel. Tax Matters Partner v. United StatesCourt of Appeals for the First Circuit · 2011
  3. 106 Ltd. v. Comm'rUnited States Tax Court · 2011
  4. NPR Investments, L.L.C. Ex Rel. Roach v. United StatesCourt of Appeals for the Fifth Circuit · 2014
  5. Alpha I, L.P. Ex Rel. Sands v. United StatesCourt of Appeals for the Federal Circuit · 2012

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