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436, LTD. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 23525-05.

T.C. Memo. 2015-28

436, LTD., ROBERT HEITMEIER, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 18, 2015.

Attorney(s) appearing for the Case

Kyle R. Coleman , for petitioner.

Richard J. Hassebrock , Nancy B. Herbert , and Gary R. Shuler, Jr. , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HOLMES, Judge.

This case comes to us from a riverboat casino on the lower Mississippi. In 1991 Robert Heitmeier saw a lucrative opportunity in the newly legalized riverboat-gambling industry of New Orleans. He started several businesses to provide crews and consulting services to these new casinos, and in 2001 Heitmeier hit the jackpot when Harrah's purchased his piloting contract with the Showboat Casino for $4 million...

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