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PRATI v. U.S.

Nos. 2008-5117, 2008-5129.

603 F.3d 1301 (2010)

Ronald C. PRATI and Mary G. Prati, Plaintiffs-Appellants, v. UNITED STATES, Defendant-Appellee. Edward J. Deegan and Joan S. Deegan, Plaintiffs-Appellants, v. United States, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

May 5, 2010.

Attorney(s) appearing for the Case

Thomas E. Redding, Redding & Associates, P.C., of Houston, TX, argued for all plaintiffs-appellants. With him on the brief were Sallie W. Gladney and Teresa J. Womack.

Deborah K. Snyder, Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee. With her on the brief were John A. DiCicco, Acting Assistant Attorney General, and Michael J. Haungs, Attorney.

Before RADER, BRYSON, and MOORE, Circuit Judges.

BRYSON, Circuit Judge.

These two federal tax cases raise complex questions pertaining to the taxation of transactions involving partnerships. Our analysis is relatively straightforward, however, because prior decisions of this court in related cases have dealt with and resolved several of the issues that are before us in these cases. Those decisions largely dictate the results we reach here.

I

The dispute in these cases relates to a number of limited...

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