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CURTIS INV. COMPANY, LLC v. C.I.R.

No. 17-14573.

909 F.3d 1339 (2018)

CURTIS INVESTMENT COMPANY, LLC, Plaintiff-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

December 6, 2018.

Attorney(s) appearing for the Case

David DeCoursey Aughtry , Jasen D. Hanson , Hale E. Sheppard , Chamberlain Hrdlicka White Williams & Aughtry, Atlanta, GA, for Petitioner-Appellant.

Jennifer Marie Rubin , Arthur Thomas Catterall , Teresa E. McLaughlin , Gilbert Steven Rothenberg , U.S. Department of Justice, Chief Appellate Section Tax Division, William M. Paul , Internal Revenue Service, Acting Chief Counsel, Washington, DC, Jason P. Oppenheim , John W. Sheffield, III , Office of Chief Counsel-IRS, Atlanta, GA, for Respondent-Appellee.

Before WILSON and JORDAN, Circuit Judges, and GRAHAM, District Judge.

In 2000, Curtis Investment Company (CIC) entered into a tax avoidance scheme known as a CARDS transaction, allowing it to claim a $27,724,620 capital loss on its annual tax return. In 2007, the Internal Revenue Service (IRS) Commissioner issued a Final Partnership Administrative Adjustment (FPAA) disallowing CIC's claimed...

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