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).
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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 9:53:31 PM