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KORNMAN & ASSOCIATES, INC. v. U.S.

No. 06-11422.

527 F.3d 443 (2008)

KORNMAN & ASSOCIATES, INC., as tax matters partner for Valiant Investments 99-100, LP, a TEFRA Partnership, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee. Colm Producer, Inc., as tax matters partner for GMK-GMK II, LP, a TEFRA Partnership, Plaintiff-Appellant, v. United States of America, Defendant-Appellee. Ettman Family Trust I, a 5-percent group of Valiant Investments 99-100, LP, a TEFRA Partnership, Plaintiff-Appellant, v. United States of America, Defendant-Appellee. Ettman Family Trust I, a partner of GMK-GMK II, LP, a TEFRA Partnership, Plaintiff-Appellant, v. United States of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

May 12, 2008.

Attorney(s) appearing for the Case

Cole B. Ramey, Crouch & Inabnett, Jeffrey Mark Tillotson (argued), Lynn, Tillotson & Pinker, Dallas, TX, for Plaintiffs-Appellants.

Joan I. Oppenheimer (argued), Richard Bradshaw Farber, Gilbert S. Rothenberg, U.S. Dept. of Justice, Tax Div. App. Section, Washington, DC, Michelle C. Johns, U.S. Dept. of Justice, Tax Div., Dallas, TX, for U.S.

Before KING, DeMOSS and SOUTHWICK, Circuit Judges.

DeMOSS, Circuit Judge:

In these consolidated TEFRA partnership proceedings,1 the Government argues that the Appellants attempted to create an enormous, artificial tax loss that is devoid of any economic content by using the short sale variant of the "Son of BOSS" tax shelter.2 Through a pre-arranged series of transactions involving the short sale of Treasury Notes (T-Notes) and subsequent transfers between...

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