Russian Recovery Fund Limited v. United States

In the United States Court of Federal Claims No. 06-30T (Consolidated with No. 06-35T) (Filed: August 12, 2015) (Re-filed: January 15, 2016) ********************** RUSSIAN RECOVERY FUND LTD., RUSSIAN RECOVERY ADVISORS, L.L.C., Taxation of partnership; Tax Matters Partner, bona fide partnership; 26 U.S.C. § 704; 26 U.S.C. § Plaintiffs, 721; FPAA; economic v. substance; step transaction; Culbertson; penalties; THE UNITED STATES, reasonable reliance on tax advice Defendant. ********************** Loretta R. Richard, Boston, MA, with whom were B. John Williams, Jr., Washington, DC, Alan J. J.…