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DEL COMMERCIAL PROP. v. C.I.R.

No. 00-1313

251 F.3d 210 (2001)

Del Commercial Properties, Inc., Appellant v. Commissioner of Internal Revenue Service, Appellee

United States Court of Appeals, District of Columbia Circuit.

Decided June 8, 2001

Attorney(s) appearing for the Case

James P. Fuller argued the cause for appellant. With him on the briefs were David L. Forst, Kenneth B. Clark and William F. Colgin.

Kenneth W. Rosenberg, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Jonathan S. Cohen, Attorney. Edward T. Perelmuter, Attorney, entered an appearance.

Before: Sentelle, Tatel and Garland, Circuit Judges.

Opinion for the Court filed by Circuit Judge Sentelle.

SENTELLE, Circuit Judge:

On July 18, 1990, Delcom Financial Ltd., a Canadian corporation, took out an $18 million loan from the Royal Bank of Canada. This loan initiated a series of transactions over the next twenty-four hours, involving five companies organized in Canada, the Cayman Islands, the Netherlands Antilles, the Netherlands, and the United States—all of which were related to each other...

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