Free Motion to Compel - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS
NO. 05-231 T
(Chief Judge Damich)

JZ Buckingham Investments LLC as Tax Matters Partner of JBJZ Partners, a South Carolina general partnership,

Plaintiff,
v.

United States of America,
Defendant.

PLAINTIFF'S OBJECTIONS AND RESPONSES TO THE UNITED STATES' INTERROGATORIES (NOS. 71 THROUGH 95)

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Plaintiff hereby objects and responds to the United States' Interrogatories (Nos. 7 i

through 95), dated September 25,2007, as follows.

GENERAL OBJECTIONS
1. Plaintiff objects to all Interrogatories on the grounds that they request
information that is cumulative and duplicative of information previously provided by

Plaintiff to the United States during discovery of this case.
2. Plaintiff objects to all Interrogatories to the extent that they seek information

protected by the Attorney/Client Privilege, the Attorney Work Product Doctrine or any
other applicable privilege.

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SPECIFIC OBJECTIONS AND RESPONSES
71. State each factual or legal issue you contend are dependent upon the value of the options

on their contribution date to JBJZ Parners, describe all legal theories and principal facts
(including expert witness testimony) supporting your contention, and identify all principal
documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
72. If you contend the option transaction has a reasonable possibility of profit in the hands of

JBJZ Partners, describe all legal theories and principal facts (including expert witness testimony)
supporting your contention, and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

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73. If

you contend the amount of

the fees relating to the COBRA transaction paid to any third

party or the treatment of the same fees on the tax returns of the S corporations, parnerships or
individual partners, are at issue in this case, describe all legal theories and principal facts

(including expert witness testimony) supporting your contention and identify all principal
documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

---

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
, 74. If you contend JBJZ Partners was formed for a legal purpose under state law and are

parnerships in fact and not a factual sham, describe all legal theories and principal facts

(including expert witness testimony) for such contention, including any theories and factual
support for any claim that the parnership was organized for other reasons than the sole purpose
of avoiding federal and state income taxes and identify all principal documents that support your
contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has

well exceeded the 100 written interrogatories that it may serve 'upon a party to this
litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.

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Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in

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the event that the Court grants the United States leave to propound additional
interrogatories or otherwise orders Plaintiff

to respond to this Interrogatory.

75. Assuming JBJZ Parners is a legal partnership under state law, if you contend JBJZ

Parners was not formed and availed of for other than the sole purpose of tax avoidance by
arificially overstating basis in the parnership interest of its parners, describe all theories and

facts (including expert witness testimony) for your contention and identify all principal
documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
76. If you contend the purchase of the offsetting option transactions and their contribution to
JBJZ Partners had economic substance and were an economic sham, describe all legal theories

and principal facts (including expert witness testimony) for such contention, and identify all

documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
,,-- .-

Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in

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the event that the Court grants the United States leave to propound additional
interrogatories or otherwise orders Plaintiff

to respond to this Interrogatory.

77. If you contend the offsetting option transactions, viewed objectively, had a reasonable

possibility of profit (other than in the hands of JBJZ Partners inquired about in Interrogatory No.
72), describe all legal theories and principal facts (including expert witness testimony)

supporting your contention and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has

well exceeded the 100 written interrogatories that it may serve upon a part to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Con-rt grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
78. If you contend that absent the tax benefits, there were reasonable expectations that the

LLCs or the purported partnerships would realize a profit in excess of the fees and transaction

costs associated with the COBRA transactions, describe all legal theories and principal facts
(including expert witness testimony) supporting your contention and identify all principal
documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.

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Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in

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.the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
79. If you contend the offsetting option transactions had a non-tax business purpose other

than the creation of incomè tax losses, describe all legal theories and principal facts (including expert witness testimony) supporting your contention and identify all principal documents that
support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
80. If you contend JBJZ Partners had a non-tax business purpose, describe all legal theories
and principal facts (including expert witness testimony) supporting your contention and identify
all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiffto respond to this Interrogatory.

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,81. If

you contend JBJZ Partners (as defined under §1.701-2 oflncome Tax Regulations) was

not formed and availed of in connection with a transaction or transactions in taxable year 1999, a

principal purpose of which was to reduce substantially the present value of its partners'
aggregate federal tax liabilty in a maner that is inconsistent with the intent of Subchapter K of
the Internal Revenue Code, describe all legal theories and principal facts (including expert

witness testimony) supporting your contention and identify all principal documents that support
your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

82. If you contend that the obligations under the short positions (written call options)
transferred to JBJZ Partners do not constitute liabilties for purposes of Treasury Regulation
§ 1. 7 52-6T, the assumption of which by the partnership should reduce the purported parners'

bases in the partnership, but not below the fair market value of the purported partnership interest,
describe all legal theories and principal facts (including expert witness testimony) supporting

your contention and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

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litigation without leave of court or written stipulation under Rule 33 of the Rules of the

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Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional
interrogatories or otherwise orders Plaintiff

to respond to this Interrogatory.

83. If you contend that JBJZ Parners and its parners entered into the option(s) positions or
purchased the foreign currency or stock with a profit motive for puroses of § 165( c )(2), describe

all legal theories and principal factual support (including expert witness testimony) for such
contention, and identify all documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has

well exceeded the 100 written interrogatories that it may serve upon a part to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
84. If you contend that the offsetting (long and short) options are "separate" positions and not

in substance a "single" position, describe all legal theories and principal facts (including expert
witness testimony) supporting your contention and identify all principal documents that support
your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

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Court of Federal Claims, and no such leave of court or stipulation has been obtained.

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Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
85. What do you contend can be established under Section 723 as the adjusted bases of the
long call positions (purchased call options), and the adjusted bases of any other contributions

purportedly contributed by the parners to JBJZ Partners describe all legal theories and principal

facts (including expert witness testimony) supporting your contention and identify all principal
documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has

well exceeded the 100 written interrogatories that it may serve upon a part to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional
interrogatories or otherwise orders Plaintiff

to respond to this Interrogatory.

86. If you contend that, in the cases of a sale, exchange, or liquidation of JBJZ Parners or the

partners' partnership interest, either the purported partnerships or their purported parners have
established that the bases of

the partners' partnership interest were greater than zero for purposes

of determining gain or loss or such partners from the sale, exchange or liquidation of such
partnership interest, state what you contend the purported partnerships or their purported partners

have established the basis of the partnerships' or partners' partnership interest are, and describe
all legal theories and principal facts (including expert witness testimony) supporting your

contention and identify all principal documents that support your contention..

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ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has

well exceeded the 100 written interrogatories that it may serve upon a part to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
87. If you contend the step transaction doctrine is not applicable in this case, requiring that the individual steps of the COBRA transaction be collapsed, describe all legal theories and
principal facts (including expert witness testimony) supporting your contention and identify all
principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
88. If you contend JBJZ Partners was used for other than the conduits to create an arificially
inflated basis in the purported partners' partnership interest, which inflated basis could, in turn,
then be allocated to propert distributed to the purported subchapter S corporations upon the

prearranged dissolution of the purported partnerships, describe all legal theories and identify all

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principal documents that support your contention.

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ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

89. If you contend the creation of the disregarded entities, the partnerships and the S
corporations and the contribution of the long and short offsetting options to the partnerships and
the liquidation of the partnerships and the distribution of the partnerships' property on the

liquidation of the partnerships to the purported subchapter S corporation were not prearranged
and therefore can not be disregarded under the step transaction doctrine, describe all legal

theories and principal facts (including expert witness testimony) supporting your contention and
identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rulè 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
90. If you contended in any attempt to obtain compensation or damages from the promoters

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or other third parties in connection with your participation in the COBRA transactions, that the

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documentation for the offsetting option transactions may not reflect the reality of these
transactions, describe all legal theories and principal facts (including expert witness testimony)
supporting your contention or that you presented to the promoters or other third parties In

pressing your attempt, and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

--

91.

If you contend that the documentation for the offsetting options transactions may not

reflect the reality of these transactions, describe all legal theories and principal facts (including

expert witness testimony) supporting your contention and identify all principal documents that
support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

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92. If you contend that the parners, partnerships or disregarded entities (LLCs) were at risk,

in whole or in part, within the "at risk" rules of §465, for the short option(s) sold to Deutsche
Bank, state the amount you contend was at risk under the "at risk" rules of §465and describe all
legal theories and principal facts (including expert witness testimony) supporting your contention
and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has

well exceeded the 100 written interrogatories that it may serve upon a part to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
93. If you contend the penalties asserted in the FP AA should not be asserted, describe all

legal theories and principal facts (including expert witness testimony) supporting your contention
and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

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94. If you contend JBJZ Partners or its parners had a reasonable belief the positions taken on
the Form 1065 partnership returns and Form 1 120S Subchapter S returns were more likely than

not the correct treatment of the tax shelter and related transactions, describe all legal theories and

principal facts (including expert witness testimony) supporting your contention and identify all
principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in
the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.
95. Do you contend that the COBRA transaction which you entered into is not a "tax shelter"
within the meaning of Section 6662(d)(2)(C)? If

you contend that the COBRA transaction which

you entered into is not a "tax shelter" within the meaning of Section 6662(d)(2)(C), describe all
legal theories and principal facts (including expert witness testimony) supporting your contention
and identify all principal documents that support your contention.

ANSWER: Plaintiff objects to this Interrogatory on the grounds that the United States has
well exceeded the 100 written interrogatories that it may serve upon a party to this

litigation without leave of court or written stipulation under Rule 33 of the Rules of the

Court of Federal Claims, and no such leave of court or stipulation has been obtained.
Plaintiff hereby reserves its right to assert any additional objections to this Interrogatory in

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the event that the Court grants the United States leave to propound additional

interrogatories or otherwise orders Plaintiff to respond to this Interrogatory.

Respectfully submitted,

By:

~~~ .tJoel N. Crouch Texas State Bar No.05144220

MEADOWS, OWENS, COLLIER, REED COUSINS & BLAU, L.L.P. 901 Main Street, Suite 3700 Dallas, TX 75202 (214) 744-3700 Telephone
(214) 747-3732 Facsimile

jcrouch~meadowsowens.com
ATTORNEYS FOR PLAINTIFF

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CERTIFICATE OF SERVICE
On this the 26th day of October, 2007, a copy of the foregoing Plaintiffs Objections and

Responses to the United States' Interrogatories (Nos. 71 through 95) was delivered to counsel
listed below via the means indicated.

Via Federal Express
Dennis M. Donohue, Esq. United States Department of Justice Tax Division Civil Trial Section, Northern Region 555 Fourth Street, N.W., Room 7804
Washington, D.C. 20001

-d ~ l-. CJ
Joel N. Crouch

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