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SUGARLOAF FUND LLC v. COMMISSIONER

Docket No. 671-10.

141 T.C. 214 (2013)

SUGARLOAF FUND LLC, JETSTREAM BUSINESS LIMITED, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 5, 2013.

Attorney(s) appearing for the Case

John E. Rogers (an officer), for petitioner.

Joseph A. DiRuzzo III, for participating partner Timothy J. Elmes.

Ronald S. Collins, Jr., for respondent.

OPINION

WHERRY, Judge:

The petition in this case was filed by Jetstream Business Limited (Jetstream) as tax matters partner for Sugarloaf Fund, LLC (Sugarloaf), on January 8, 2010. On July 12, 2012, Timothy J. Elmes filed an election to participate in this case pursuant to section 6226(c).1 On July 19, 2012, Mr. Elmes filed a motion requesting that the Court stay consolidation of this case with other transactionally related...

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