7th Circ. Asks If Changes Truly Transformed Tax Shelter

Law360 (February 14, 2020, 5:16 PM EST) -- A Seventh Circuit judge on Friday pushed an ex-Seyfarth partner to address whether rollups of trading companies and investor trusts did enough to "clean the sham status" of a partnership found to be a tax shelter in the early 2000s, as the partnership now asks the court to reject IRS adjustments for later tax years.

U.S. Circuit Judge Michael Scudder asked John Rogers, a solo attorney who was a Seyfarth Shaw LLP partner when he designed Sugarloaf Fund LLC, to address whether restructured management was transformative enough to "take us from a sham circumstance to a non-sham circumstance" if "Sugarloaf was...

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