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SARMA v. C.I.R.

No. 21-12303.

45 F.4th 1312 (2022)

Raghunathan SARMA & Gaile Sarma, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

Filed: August 19, 2022.

Attorney(s) appearing for the Case

Charles E. Hodges, II , Aditya Shrivastava , Attorney, Jones Day, Atlanta, GA, for Petitioners-Appellants.

Douglas Campbell Rennie , Arthur Thomas Catterall , Jacob Earl Christensen , Francesca Ugolini , U.S. Department of Justice, Appellate Section Tax Division, Michael J. Desmond , Chief Counsel-IRS, Washington, DC, for Respondent-Appellee.

Before Newsom, Marcus, Circuit Judges, and Middlebrooks, District Judge.

This appeal involves the tax consequences of Raghunathan Sarma's participation in a complex tax avoidance scheme. In 2001, Sarma expected to realize an $80.9 million capital gain as a result of selling a portion of his company. The scheme, which involved a set of tiered partnerships, allowed Sarma to claim a $77.6 million...

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