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SUGARLOAF FUND v. COMMISSIONER OF INTERNAL REVENUE

No. 19-2468.

953 F.3d 439 (2020)

SUGARLOAF FUND, LLC and Jetstream Business Limited, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided March 6, 2020.

Attorney(s) appearing for the Case

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

Arthur T. Catterall , Geoffrey Klimas , Attorneys, Department of Justice, Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.

Before Ripple, Sykes, and Scudder, Circuit Judges.

Before us for a third time is a tax shelter designed by attorney John Rogers that the Tax Court has determined is an abusive sham. We reached the same conclusion in our prior opinions in Superior Trading, LLC v. Commissioner, 728 F.3d 676 (7th Cir. 2013), and Sugarloaf Fund, LLC...

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