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Maguire Partners - Master Investments, LLC v. United States

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION


March 3, 2009

MAGUIRE PARTNERS - MASTER INVESTMENTS, LLC, MAGUIRE PARTNERS, INC., TAX MATTERS PARTNERS, ET AL., PLAINTIFFS,
v.
UNITED STATES OF AMERICA DEFENDANT.

The opinion of the court was delivered by: John F. Walter United States District Judge

Judgment

For the reasons set forth in the Court's findings of fact and conclusions of law, dated February 4, 2009, (dkt. 140), the Court denies Plaintiffs' request to readjust partnership items for 2001 and 2002 of Maguire Partners - Master Investments, LLC; Thomas Division Partnership, L.P.; Thomas Investment Partners, Ltd.; Thomas Master Investments, L.P.; and Huntington/Fox Investments, L.P. The adjustments set forth in the Notices of Final Partnership Administrative Adjustments (FPAAs) are correct. Further, the accuracy-related penalties specified in the FPAAs were appropriately imposed and there are no partnership-level defenses to those penalties.

Judgment is entered in favor of the United States and against Maguire Partners - Master Investments, LLC, Maguire Partners, Inc., Tax Matters Partner, in case no. CV 06-7371; Thomas Division Partnership, L.P., Thomas Investment Partners, Ltd., Tax Matters Partner, in case no. CV 06-7374; Thomas Investment Partners, Ltd., Thomas Partners, Inc., Tax Matters Partner, in case no. CV 06-7376; Thomas Master Investments, L.P., Thomas Partners, Inc., Tax Matters Partner, in case no. CV 06-7377; and Huntington/Fox Investments, L.P., Edward D. Fox, Jr., Tax Matters Partner, in case no. CV 06-7380.

The United States is entitled to costs pursuant to Rule 54(d)(1), Federal Rules of Civil Procedure, in amounts to be determined.

IT IS SO ORDERED:

20090303

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