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KLAMATH STRATEGIC INV. FUND, LLC v. U.S.

Civil Action No. 5:04-CV-278.

472 F.Supp.2d 885 (2007)

KLAMATH STRATEGIC INVESTMENT FUND, LLC v. UNITED STATES of America.

United States District Court, E.D. Texas, Texarkana Division.

January 31, 2007.

Attorney(s) appearing for the Case

Kent L. Jones, N. Jerold Cohen, Sheldon M. Kay, Thomas A. Cullinan, Sutherland Asbill & Brennan, Atlanta, GA, for Klamath Strategic Investment Fund, LLC.

Andrew L. Sobotka, U.S. Attorney Office, Department of Justice, Tax Division, Dallas, TX, Stuart David Gibson, Jennifer Kirkpatrick Brown, U.S. Department of Justice, Tax Division, Washington, DC, for United States of America.

MEMORANDUM OPINION AND ORDER

WARD, District Judge.

Pursuant to Fed.R.Civ.P. 52, the court issues the following memorandum opinion and order, which constitutes the court's findings of fact and conclusions of law.1

1. Introduction.

This case involves a tax shelter known as Bond Linked Issue Premium Structure ("BLIPS"). It is a civil action by the plaintiffs against the United States under 26...

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