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SOUTHGATE MASTER FUND, L.L.C. v. U.S.

No. 09-11166.

659 F.3d 466 (2011)

SOUTHGATE MASTER FUND, L.L.C., by and through MONTGOMERY CAPITAL ADVISORS, LLC its Tax Matters Partner, Plaintiff-Appellant-Cross-Appellee, v. UNITED STATES of America, Defendant-Appellee-Cross-Appellant.

United States Court of Appeals, Fifth Circuit.

September 30, 2011.

Attorney(s) appearing for the Case

Michael Todd Welty , SNR Denton, L.L.P., Dallas, TX, Roy Theodore Englert, Jr. , (argued), Robbins, Russell, Englert, Orseck, Untereiner & Sauber, L.L.P., Washington, D.C., for Plaintiff-Appellant-Cross-Appellee.

Judith Ann Hagley , (argued), Kenneth L. Greene , Supervisory Atty., Tax Div., App. Section, Gilbert Steven Rothenberg , Depty Asst. Atty., Gen., U.S. Dept. of Justice, Washington, DC, David Gray Adams , Tax Div., U.S. Dept. of Justice, Dallas, TX, for Defendant-Appellee-Cross-Appellant.

Before JOLLY, HIGGINBOTHAM and SMITH, Circuit Judges.

PATRICK E. HIGGINBOTHAM, Circuit Judge.

We affirm in all respects the district court's judgment disposing of this petition for a readjustment of partnership tax items under 26 U.S.C. § 6226. The plaintiff, Southgate Master Fund, L.L.C., was formed for the purpose of facilitating the acquisition of a portfolio of Chinese nonperforming loans ("NPLs"). A partnership for tax purposes, Southgate's disposition of its portfolio of NPLs generated more than $1 billion...

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