CHEMTECH ROYALTY ASSOCIATES, L.P., as Tax Matters Partner Real Party in Interest Dow Europe, S.A., Plaintiff-Appellant Cross-Appellee,
v.
UNITED STATES of America, Defendant-Appellee Cross-Appellant.
Chemtech Royalty Associates, L.P., by Dow Europe, S.A. as Tax Matters Partner, Plaintiff-Appellant Cross-Appellee,
v.
United States of America, Defendant-Appellee Cross-Appellant.
Chemtech II, L.P., Plaintiff-Appellant Cross-Appellee,
v.
United States of America, Defendant-Appellee Cross-Appellant.
Chemtech II, L.P. By Ifco, Incorporated, as Tax Matters Partner, Plaintiff-Appellant Cross-Appellee,
v.
United States of America, Defendant-Appellee Cross-Appellant.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
This appeal concerns the tax consequences of two transactions undertaken by Dow Chemical Company ("Dow") and a number of foreign banks1 from 1993 through 2006. During those years, Dow and the foreign banks purported to operate two partnerships that generated over one billion dollars in tax deductions for Dow. After a five-day trial, the district court disregarded the partnerships for tax purposes on three...
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