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ASA INVESTERINGS PARTNERSHIP v. C.I.R.

No. 98-1583.

201 F.3d 505 (2000)

ASA INVESTERINGS PARTNERSHIP, et al., Appellants v. COMMISSIONER OF INTERNAL REVENUE, Appellee

United States Court of Appeals, District of Columbia Circuit.

Decided February 1, 2000.

Attorney(s) appearing for the Case

Jerome B. Libin argued the cause for appellants. With him on the briefs was Steuart H. Thomsen.

Edward T. Perelmuter, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief were Loretta C. Argrett, Assistant Attorney General, and Richard Farber, Attorney.

Before: WILLIAMS, SENTELLE and HENDERSON, Circuit Judges.

Opinion for the Court filed by Circuit Judge STEPHEN F. WILLIAMS.

STEPHEN F. WILLIAMS, Circuit Judge:

In January 1990 AlliedSignal, a company manufacturing aerospace and automotive products, decided to sell its interest in Union Texas Petroleum Holdings, Inc., an oil, gas, and petrochemical company. Anticipating a large capital gain, it sought to reduce the resulting tax burden by entering into a set of transactions via a partnership with several foreign corporations...

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