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The infamous “carried interest” treatment enjoyed by hedge fund and venture capital fund managers may be at risk in the wake of the Tax’s Court’s decision in Dagres v. Commissioner, 136 T.C. No. 12 (March 28, 2011). Although the Tax Court didn’t directly assault the carried interest “loophole” in Dagres, some commentators think it may have opened the door for the Treasury and the IRS.


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