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Monday, February 9, 2009

District Court Rejects Arthur Andersen Call-Option Spread Partnership Transactions

A federal district court in California last week applied the economic substance, step transaction, and substance over form doctrines in disregarding a call-option spread partnership transaction markteted by Arthur Andersen.  Maguire Partners - Master Investments LLC v. United States, No. 06-07371 (C.D. CA Feb. 4, 2009).

http://taxprof.typepad.com/taxprof_blog/2009/02/district-court-rejects-arthur-andersen-calloption-spread-partnnership-transactions.html

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Comments

This is the money quote.

One of the plaintiff's "Thomas, a former
trial attorney with the I.R.S.,"

Posted by: Justin | Feb 9, 2009 6:53:31 PM