The IRS has again issued guidance indicating their displeasure with a marketed shelter that promises benefits via the literal application of partnership provisions in the IRC.  In CCA 200704028 the IRS outlines both the shelter that was marketed that claimed the magic of returning most of the investment via a credit against state taxes and then a capital loss deduction for the investment for federal tax purposes as well.  The IRS outlines three separate rationales for disallowing the claimed treatment.The materials for the podcast can be downloaded from http://edzollars.com/2007-02-24_Credit_Denied.pdf .The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .