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RB-1 INVESTMENT PARTNERS v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 22674-04.

T.C. Memo. 2018-64

RB-1 INVESTMENT PARTNERS, ERIC REINHART, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 14, 2018.

Attorney(s) appearing for the Case

Kyle R. Coleman , for petitioner.

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

MEMORANDUM FINDINGS OF FACT AND OPINION

The Reinhart brothers made a fortune when they sold their family concrete business in 2000, but the sale threatened a hefty tax liability. The brothers chose to enter a Son-of-BOSS1 deal to manufacture tax losses to offset their gains. They concede the...

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