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  5. 747 F.Supp.2d 49 (2010)
 

FIDELITY INTERN. CURRENCY ADVISOR A FUND v. U.S.

Civil Nos. 05-40151-FDS, 06-40130-FDS, 06-40243-FDS, 06-40244-FDS.

747 F.Supp.2d 49 (2010)

FIDELITY INTERNATIONAL CURRENCY ADVISOR A FUND, LLC, BY the TAX MATTERS PARTNER, Plaintiff, v. UNITED STATES of America, Defendant. Fidelity High Tech Advisor a Fund, LLC, by the Tax Matters Partner, Plaintiff, v. United States of America, Defendant.

United States District Court, D. Massachusetts.

October 18, 2010.

Attorney(s) appearing for the Case

David J. Curtin , James D. Bridgeman , Kiara Rankin , Ronald L. Buch , Sheri A. Dillon , William F. Nelson , Bingham McCutchen LLP, Washington, DC, John O. Mirick , David K. McCay , Mirick, O'Connell , Demallie & Lougee, Worcester, MA, for Plaintiffs.

Dennis M. Donohue , Barry E. Reiferson , Heather L. Vann , John Lindquist , U.S. Department of Justice, Washington, DC, for Defendants.

AMENDED [CORRECTED] FINDINGS OF FACT AND CONCLUSIONS OF LAW

SAYLOR, District Judge.

This is a dispute concerning two complex tax shelter transactions. The plaintiffs in these consolidated actions are Fidelity International Currency Advisor A Fund, LLC and Fidelity High Tech Advisor A Fund, LLC. The tax matters partner, and the principal taxpayer who invested in and benefitted from the tax shelter transactions at issue, was Richard J. Egan.

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