Salina Partnership LP, FPL Group, Inc., A Partner Other Than the Tax Matters Partner, Petitioner, v. Commissioner of Internal Revenue, Respondent, U.S. Tax Court Docket No. 25084-95.  In this case, the IRS alleged that Florida Power and Light engaged in a series of financial transactions whose sole purpose was to refresh an expiring capital loss carry-forward.

Zeelandia Investorings Partnership, BFI, Inc. Tax Matters Partner, Petitioner, v. Commissioner of Internal Revenue, Respondent, U.S. Tax Court Docket No. 12927-95. In this case, the IRS alleged that Borden Foods engaged in an offshore partnership and transacted certain securities for the sole purpose of creating a paper capital loss to offset a gain occasioned from an asset sale.

Compaq Computer Corporation and Subsidiaries, Petitioner, v. Commissioner of Internal Revenue, Respondent, U.S. Tax Court Docket No. 24238-96.  In this case, the IRS alleged that Compaq engaged in a series of cross trades involving nearly $1billion of Royal Dutch Shell American Depository Receipts in order to produce a paper capital loss and shelter gains.

Boca Investerings Partnership, American Home Products Corporation, Tax Matters Partner, Plaintiff, v. United States of America, Defendant, Civil Action 97-CV-602 (PFL).  Here the Tax Division of the Department of Justice alleged that AHP engaged in an offshore partnership and a series of securities transactions designed to shelter an approximately $600 million capital gain occasioned by a division sale.

ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner, Petitioner, v. Commissioner of Internal Revenue, Respondent, U.S. Tax Court Docket No. 10472-93.  Also known as the "Colgate case", the publication Tax Notes called this case "the litmus test of the Clinton Treasury administration's attempt to put bite back into the business purpose doctrine".