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CEMCO INVESTORS, LLC v. U.S.

No. 07-2220.

515 F.3d 749 (2008)

CEMCO INVESTORS, LLC, and Forest Chartered Holdings, Ltd., Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided February 7, 2008.

Attorney(s) appearing for the Case

Thomas D. Sykes (argued), McDermott, Will & Emery, Chicago, IL, for Plaintiffs-Appellants.

Arthur T. Catterall (argued), Department of Justice, Civil Division, Immigration Litigation, Washington, DC, for Defendant-Appellee.

Before EASTERBROOK, Chief Judge, and MANION and KANNE, Circuit Judges,

EASTERBROOK, Chief Judge.

Paul M. Daugerdas, a tax lawyer whose opinion letters while at Jenkins & Gilchrist led to the firm's demise (it had to pay more than $75 million in penalties on account of his work), designed a tax shelter for himself, with one client owning a 37% share. Like many tax shelters it was complex in detail but simple in principle, and to facilitate exposition we cover only its basics, rounding all figures.

Four entities played a role...

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