Free Memorandum - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 160-2

Filed 03/07/2008

Page 1 of 1

IN THE UNITED STATES DISTRICT COURT OF FEDERAL CLAIMS JZ Buckingham Investments, LLC, as Tax Matters Partner of JBJZ Partners, A South Carolina general partnership, Plaintiff, v. United States of America, Defendant. § § § § § § § § § § §

Case No. 05-231 T Chief Judge Edward Damich

APPENDIX A TO MEMORANDUM IN SUPPORT OF ITS MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE VALIDITY OF TREASURY REGULATION § 1.752-6 Exhibit A.1. A.2. A.3. A.4. A.5. A.6. A.7. A.8. A.9. A.10. Description Certified Delaware Filings for JZ Buckingham Investments, LLC Certified Delaware Filings for JGB Bohicket Investments, LLC Partnership Agreement for JBJZ Partners Digital Option Agreement for JGB Bohicket Investments, LLC Digital Option Agreement for JZ Buckingham Investments, LLC Digital Option Agreement for JZ Buckingham Investments, LLC Assignment Agreement for JZ Buckingham Investments, LLC Assignment Agreement for JZ Buckingham Investments, LLC Assignment Agreement for JGB Bohicket Investments, LLC IRS FPAA to JBJZ Partners Pages 1-2 3-4 5-16 17-19 20-22 23-25 26-28 29-31 32-34 35-46

APPENDIX A ­ Page 1 364657