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  5. 714 F.Supp.2d 598 (2010)
 

NEVADA PARTNERS FUND, LLC EX REL. SAPPHIRE v. U.S.

Civil Action No. 3:06cv379-HTW-MTP. Nos. 3:06-cv-384 HTW-MTP, 3:06-cv-385 HTW-MTP, 3:06-cv-386 HTW-MTP, 3:06-cv-387 HTW-MTP, 3:06-cv-380 HTW-MTP, 3:06-cv-381 HTW-MTP, 3:06-cv-382 HTW-MTP, 3:06-cv-388 HTW-MTP, 3:06-cv-389 HTW-MTP, 3:06-cv-390 HTW-MTP.

714 F.Supp.2d 598 (2010)

NEVADA PARTNERS FUND, LLC, by and through SAPPHIRE II, INC., the tax matters partner, Plaintiff v. UNITED STATES of America, Defendant.

United States District Court, S.D. Mississippi, Jackson Division.

April 30, 2010.

Attorney(s) appearing for the Case

Alveno N. Castilla , W. Whitaker Rayner , Watkins Ludlam Winter & Stennis, P.A., Sheryl M. Bey, Baker , Donelson, Bearman, Caldwell & Berkowitz, PC, Jackson, MS, Charles E. Hodges, PHV, II , David D. Aughtry, PHV , Chamberlain, Hrdlicka, White, Williams & Martin, Atlanta, GA, for Plaintiff.

Michael N. Wilcove , Pascale Guerrier , Paul A. Allulis , U.S. Dept. of Justice, Tax Division, Washington, DC, for Defendant.

MEMORANDUM OPINION AND ORDER

HENRY T. WINGATE, Chief Judge.

Before this court is a federal income tax partnership proceeding tried to the court sitting without a jury between the dates of August 3, 2009, and September 23, 2009. Now, pursuant to Rule 52,1 Federal Rules of Civil Procedure, this court announces its findings of fact and conclusions of law.

This lawsuit was brought by Nevada Partners Fund, LLC, by and...

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