NEVADA PARTNERS FUND, L.L.C. v. U.S.

NEVADA PARTNERS FUND, L.L.C., by and through SAPPHIRE II, INCORPORATED, Tax Matters Partner, Plaintiff-Appellant Cross-Appellee v. UNITED STATES of America, by and through its agent, the INTERNAL REVENUE SERVICE, Defendant-Appellee Cross-Appellant Carson Partners Fund, L.L.C., by and through Sapphire II, Incorporated, Tax Matters Partner, Plaintiff-Appellant Cross-Appellee v. United States of America, by and through its agent, the Internal Revenue Service, Defendant-Appellee Cross-Appellant Reno Partners Fund, L.L.C., by and through Carson Partners Fund, L.L.C., Tax Matters Partner, Plaintiff-Appellant Cross-Appellee v. United States of America, by and through its agent, the Internal Revenue Service, Defendant-Appellee Cross-Appellant Carson Partners Fund, L.L.C., by and through Nevada Partners Fund, L.L.C., Tax Matters Partner, Plaintiff-Appellant Cross-Appellee v. United States of America, by and through its agent, the Internal Revenue Service, Defendant-Appellee Cross-Appellant Reno Partners Fund, L.L.C., by and through Delta Currency Management Company, Tax Matters Partner, Plaintiff-Appellant Cross-Appellee v. United States of America, by and through its agent, the Internal Revenue Service, Defendant-Appellee Cross-Appellant Carson Partners Fund, L.L.C., by and through Bricolage Capital Management Company, Tax Matters Partner, Plaintiff-Appellant Cross-Appellee v. United States of America, by and through its agent, the Internal Revenue Service, Defendant-Appellee Cross-Appellant Nevada Partners Fund, L.L.C., by and through Bricolage Capital Management Company, Tax Matter Partner, Plaintiff-Appellant Cross-Appellee v. United States of America, by and through its agent, the Internal Revenue Service, Defendant-Appellee Cross-Appellant.