Legal Opinion
Cemco Investors, LLC v. United States
Court of Appeals for the Seventh Circuit
Decided February 7, 2008No. 07-2220PublishedCited by 34 opinions
1Opinion of the Court
EASTERBROOK, Chief Judge.
Paul M. Daugerdas, a tax lawyer whose opinion letters while at Jenkins & Gilchrist led to the firm’s demise (it had to pay more than $75 million in penalties on account of his work), designed a tax shelter for himself, with one client owning a 37% share. Like many tax shelters it was complex in detail but simple in principle, and to facilitate exposition we cover only its basics, rounding all figures.
Four entities played a role: Cemco Investors, a limited liability company that for tax purposes is treated as a partnership (so that its profits and losses are passed…
2Cases cited7 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. Fior D'Italia, Inc.Supreme Court of the United States · 2002
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Roberts v. CommissionerUnited States Tax Court · 1990
2 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Marriott International Resorts, L.P. v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Kornman & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2008
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- American Boat Co., LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2009
29 more not listed; retrieve them via the Exa API.