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DYNAMO HOLDINGS LIMITED PARTNERSHIP v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 2685-11, 8393-12.

T.C. Memo. 2018-61

DYNAMO HOLDINGS LIMITED PARTNERSHIP, DYNAMO, GP, INC., TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, BEEKMAN VISTA, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 7, 2018.

Attorney(s) appearing for the Case

Martin R. Press , Edward A. Marod , Clinton R. Losego , Lu-Ann M. Dominguez , Alan S. Lederman , and John W. Terwilleger , for petitioners.

David B. Flassing , Lisa M. Goldberg , William G. Merkle , Timothy A. Sloane , and G. Roger Markley , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

The Moog family has been very successful in real estate development. Their real estate business originated in Canada. When it expanded into the United States, they created U.S. subsidiaries under the Canadian structure. Over time some family members and beneficial owners of the Canadian...

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