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SUPERIOR TRADING, LLC v. C.I.R.

Nos. 12-3367, 12-3370, 12-3368, 12-3371, 12-3369.

728 F.3d 676 (2013)

SUPERIOR TRADING, LLC, et al., Petitioners-Appellants, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 26, 2013.

Attorney(s) appearing for the Case

John Edward Rogers (submitted), Attorney, Rogers & Associates, Chicago, IL, for Petitioner-Appellant.

Ellen P. Delsole (submitted), Tamara W. Ashford , Richard Farber , Attorneys, Department of Justice, Washington, DC, for Respondent-Appellee.

Before EASTERBROOK, Chief Judge, and POSNER and WILLIAMS, Circuit Judges.

POSNER, Circuit Judge.

These appeals are by multiple LLCs (limited-liability companies) involved in the creation and administration of a tax shelter. For the sake of simplicity we'll treat the appeals as one appeal, by Warwick Trading, LLC. The other appellants are subsidiaries of Warwick used to attract investors in it and needn't be discussed separately. The appeal challenges a decision by the Tax Court upholding the disallowance...

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