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RUSSIAN RECOVERY FUND LTD. v. U.S.

No. 06-30T, Consolidated with No. 06-35T.

RUSSIAN RECOVERY FUND LTD., RUSSIAN RECOVERY ADVISORS, L.L.C., Tax Matters Partner, Plaintiffs, v. THE UNITED STATES, Defendant.

United States Court of Federal Claims.

January 15, 2016.

Attorney(s) appearing for the Case

RUSSIAN RECOVERY FUND LIMITED, Russian Recovery Advisors, L.L.C., Tax Matters Partner,, Plaintiff, represented by Loretta R. Richard, Ropes & Gray, LLP.

USA, Defendant, represented by Robert J. Higgins, U. S. Department of Justice.

OPINION

This is a Tax Equity and Fiscal Responsibility Act ("TEFRA") action seeking readjustment of partnership items involving what has come to be known as a "DAD" transaction. That is a distressed asset/debt ("DAD") transaction in which losses suffered by a tax indifferent entity are transferred to a partnership...

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