Legal Opinion
Sugarloaf Fund, LLC, Jetstream Business Limited, Tax Matters Partner v. Commissioner
United States Tax Court
Decided September 5, 2013No. 671-10Published
1Opinion of the Court
141 T.C. No. 4
UNITED STATES TAX COURT SUGARLOAF FUND LLC, JETSTREAM BUSINESS LIMITED, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 671-10. Filed September 5, 2013. 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…
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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