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SUGARLOAF FUND, LLC v. C.I.R.

No. 18-1046.

911 F.3d 854 (2018)

SUGARLOAF FUND, LLC, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided December 21, 2018.

Attorney(s) appearing for the Case

John Edward Rogers , Attorney, Rogers & Associates, Evanston, IL, for Petitioner-Appellant.

Paul Andrew Allulis , Joan I. Oppenheimer , Attorneys, Department of Justice, Tax Division, Appellate Section, Gilbert Steven Rothenberg , Attorney, Department of Justice, Office of the Attorney General, Washington, DC, for Respondent-Appellee.

Before Ripple, Sykes, and Scudder, Circuit Judges.

Before us in this appeal is a tax shelter almost identical to the one we agreed reflected an abusive sham in Superior Trading, LLC v. Commissioner, 728 F.3d 676 (7th Cir. 2013). We reach the same conclusion here and affirm the Tax Court's judgment and imposition of penalties.

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