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This document summarizes a court case involving Robert Nagy, who provided tax advice to Derivium companies regarding their "90% Loan Program." The district court granted partial summary judgment finding the loans were actually sales for tax purposes. At trial, the jury found Nagy liable under § 6700 for promoting abusive tax shelters. Nagy appealed various rulings. The appellate court affirmed in part, reversed in part, vacating the jury verdict and remanding for a new trial.

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Scribd Government Docs

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