United States DC Circuit

A partnership with a foreign corporation in a tax-free jurisdiction whose primary purpose is to generate tax losses for the domestic partner and tax gains for the foreign partner may be a sham partnership.

Appellate Information

• Argued 10/02/2001
• Decided 12/21/2001
• Published 12/21/2001

Judges

• Before:  EDWARDS, ROGERS and TATEL, Circuit Judges.

Court

• United States DC Circuit

Counsel

• For Appellees:
  
• Thomas C. Durham argued the cause for appellants/cross-appellees.   With him on the briefs was Joel V. Williamson., Richard Farber, Attorney, U.S. Department of Justice, argued the cause for appellee/cross-appellant.   With him on the briefs was Edward T. Perelmuter, Attorney.  Stuart L. Brown, Attorney, Internal Revenue Service, entered an appearance.