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ENDEAVOR PARTNERS FUND, LLC v. C.I.R.

No. 18-1275 Consolidated with 18-1276, 18-1277, 18-1278.

943 F.3d 464 (2019)

ENDEAVOR PARTNERS FUND, LLC and Delta Currency Trading, LLC, Tax Matters Partner, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided November 26, 2019.

Attorney(s) appearing for the Case

Adrienne B. Koch , New York, NY, argued the cause for appellants. With her on the briefs were David L. Katsky , Elias M. Zuckerman , and Haley E. Adams , New York, NY.

Francesca Ugolini , Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was Judith A. Hagley , Attorney.

Concurring opinion filed by Circuit Judge Rogers.

Andrew Beer was in the tax shelter business. His enterprise (referred to by the parties as "the Delta Group" or "Bricolage") sold customers the chance to claim large, artificial losses to offset their income and reduce their taxes. Partnerships controlled by Beer bought pairs...

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