« Graetz Publishes 2008 Woodworth Lecture on Tax Policy Challenges | Main | Pareja: Taxation Without Liquidation: Rethinking "Ability to Pay" »
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).
February 9, 2009 in New Cases, Tax | Permalink
TrackBack
TrackBack URL for this entry:
http://www.typepad.com/services/trackback/6a00d8341c4eab53ef0105371ad86e970b
Listed below are links to weblogs that reference District Court Rejects Arthur Andersen Call-Option Spread Partnership Transactions:
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 9:53:31 PM
