Thursday, December 17, 2009

Palm Canyon X Investments, LLC

This case involves some celebrity.

Palm Canyon X Investments, LLC through AH Investment Holdings, Inc., its tax matters partner, challenged the IRS in the United States Tax Court. The Tax Court filed its opinion on December 15, 2009. The IRS won the case. The case involves tax shelter-type issues. Palm Canyon, a single-member limited liability company owned by AH Investment Holdings, entered into some contracts known as "offsetting market-linked deposit contracts." So what? you say. Well, it was all important enough for a judge to write a 104 page opinion, including his conclusion that Palm Canyon was a farce --- a sham --- and that the market-linked deposit contracts lacked economic substance and could be disregarded. Of course, I won't be giving all the details here, but it is interesting to note that the case involves the actress, Suzanne Somer, and her husband, Alan Hamel, and the well-known "Thighmaster" exercise equipment.

Furthermore, in this case, the government was represented --- at least in part --- by two of my former colleagues at the IRS, Stephen M. Barns and David Sorenson, who were attorneys with District Counsel. David's office was two or three offices down from mine. Stephen's --- who incidentally went by Mark, his middle name --- worked in an office down the hall and then to the left a couple of offices, almost on the other side of the building. Anyway, I thought that was interesting.

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