Chemtech Royalty Associates, L.P. v. United States of America

Filing 143

MEMORANDUM RULING: The Court finds that the Chemtech transactions and partnerships should be disregarded for tax purposes. The Court also finds that the foreign banks were not partners in Chemtech for tax purposes. Finally, the Court finds that a 20& #037; penalty applies in this case for the tax years over which this court has jurisdiction. The parties are directed to confer and submit, within 15 days, a proposed form of judgment (agreed if possible) consistent with this opinion. Signed by Chief Judge Brian A. Jackson on 02/26/2013. (NLT)

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