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ALPHA I, L.P. EX REL. SANDS v. U.S.

Nos. 2011-5024, 2011-5030.

682 F.3d 1009 (2012)

ALPHA I, L.P., (by and through Robert SANDS, a Notice Partner), Beta Partners, L.L.C., (by and through Robert Sands, a Notice Partner), R, R, M & C Partners, L.L.C., (by and through R, R, M & C Group, L.P., a Notice Partner), R, R, M & C Group L.P., (by and through Robert Sands Charitable Remainder Unitrust — 2001, a Notice Partner), CWC Partnership I, (by and through Trust FBO Zachary Stern U/A Fifth G. Andrew Stern and Marilyn Sands, Trustees, a Notice Partner), Mickey Management, L.P., (by and through Marilyn Sands, a Notice Partner), M, L, R & R, (by and through Richard E. Sands, Tax Matters Partner), Plaintiffs-Cross Appellants, v. UNITED STATES, Defendant-Appellant.

United States Court of Appeals, Federal Circuit.

June 15, 2012.

Attorney(s) appearing for the Case

Thomas A. Cullinan , Sutherland Asbill & Brennan LLP, of Atlanta, GA, argued for plaintiffs-cross appellants. With him on the brief were N. Jerold Cohen and Joseph M. Depew ; and Kent L. Jones , of Washington, DC.

Francesca U. Tamami , Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellant. With her on the brief were Gilbert S. Rothenberg , Acting Deputy Assistant Attorney General, and Kenneth L. Greene , Attorney.

Before RADER, Chief Judge, NEWMAN, and O'MALLEY, Circuit Judges.

O'MALLEY, Circuit Judge.

The U.S. Court of Federal Claims dismissed the Internal Revenue Service's determination that certain taxpayers' transfers of their partnership interests to trusts were shams because the court believed it lacked jurisdiction to address the IRS's determination at the partnership level. The United States appeals that ruling in Case No. 2011-5024. We reverse the Court of Federal Claims's dismissal. The...

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