Wednesday, March 28, 2007
The U.S. District Court for the Northern District of Illinois on Tuesday granted the Government's motion for summary judgment in yet another tax shelter case: Cemco Investors LLC v. United States, No. 04 C 8211 (N.D. Ill. 3/27/07). The particular shelter was a BLIPSS variant -- the goal was to increase the basis of a partnership through the purchase of offsetting foreign currency contracts. The judge did not buy it:
As detailed below, Cemco’s theory consists of several nuanced procedural steps. Ultimately, however, the argument amounts to little more than a house of cards, for if any of the steps fail (and several do), Cemco’s entire position collapses.
For more, see Joe Kristan.