Richard Egan Estate Subject to 40% Penalty on Doomed Shelter

I thought I was done with Fidelity International Currency Advisors back in January when I wrote the fourth post in what I call my EMC trilogy. Last December,the legal team defending EMC founder Richard Egan’s ill fated tax shelter pulled out a small victory after having lost spectacularly.  Of the $220,944.65 in litigation expenses that the feds sought to charge them with $65,896.10 was disallowed.  It was not much of a victory particularly when weighed against $80,000,000 in tax and penalty.  Perhaps emboldened by the small win, they went hunting for bigger game.  They were trying to get the penalty cut in half.  The decision, another loss for team Egan, is a good read.  It lays out the original plan in all its absurdity in a very clear manner:

http://www.forbes.com/sites/peterjreilly/2011/10/28/richard-egan-estate-subject-to-40-penalty-on-doomed-shelter/