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SABA PARTNERSHIP v. C.I.R.

Nos. 00-1328, 00-1385.

273 F.3d 1135 (2001)

SABA PARTNERSHIP, et al., Appellants/Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee/Cross-Appellant.

United States Court of Appeals, District of Columbia Circuit.

Decided December 21, 2001.

Attorney(s) appearing for the Case

Thomas C. Durham argued the cause for appellants/cross-appellees. With him on the briefs was Joel V. Williamson.

Richard Farber, Attorney, U.S. Department of Justice, argued the cause for appellee/cross-appellant. With him on the briefs was Edward T. Perelmuter, Attorney. Stuart L. Brown, Attorney, Internal Revenue Service, entered an appearance.

Before: EDWARDS, ROGERS and TATEL, Circuit Judges.

Opinion for the Court filed by Circuit Judge TATEL.

TATEL, Circuit Judge:

Through an elaborate scheme involving partnerships with a foreign bank operating in a tax-free jurisdiction, a diversified U.S. company generated over $190 million worth of tax losses while incurring an actual loss of only $5 million. The Tax Court found that because certain of the partnerships' transactions lacked economic substance, they created no gains or losses for federal tax purposes...

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