United States Seventh Circuit

In a tax case arising from a lawyer's efforts to set up a tax shelter, a judgment for the IRS disallowing an LLC's claimed $3.6 million loss and assessing a 40% penalty for its grossly incorrect tax return is affirmed primarily where, contrary to the LLC's claim, a particular regulation applies to the deal at issue and prevents its investors from claiming a loss.

Appellate Information

• Argued 12/07/2007
• Decided 02/07/2008
• Published 02/07/2008

Judges

• EASTERBROOK, Chief Judge., Before EASTERBROOK, Chief Judge, and MANION and KANNE, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

• For Appellant:
  
• Thomas D. Sykes (argued), McDermott, Will & Emery, Chicago, IL, for Plaintiffs-Appellants.


• For Appellees:
  
• Arthur T. Catterall (argued), Department of Justice, Civil Division, Immigration Litigation, Washington, DC, for Defendant-Appellee.