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TIGERS EYE TRADING, LLC v. COMMISSIONER

Docket No. 14510-05.

138 T.C. 67 (2012)

TIGERS EYE TRADING, LLC, SENTINEL ADVISORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 13, 2012.

Attorney(s) appearing for the Case

Felix B. Laughlin and Mark D. Allison, for petitioner.

David D. Aughtry, Hale E. Sheppard, and William E. Buchanan, for participating partner.

James E. Gray, for respondent.

                                   CONTENTS

                                                                            Page

Background ..............................................................    77
Discussion ..............................................................    88
I.  Introduction: Complexity of Income Tax Treatment of Partners
       and Partnerships ..................................................

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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