Promoters of tax shelters zealously guard the names of their wealthy clients. But in mounting an unusual court challenge against an Internal Revenue Service ruling that branded a certain tax shelter abusive and illegal, a promoter of the shelter has had to provide a rare glimpse of the investors who bought into it.
The list of those investors, disclosed in filings in federal court in San Francisco, reads like a who's who of rich Americans, including Edward S. Lampert, the hedge fund billionaire and chairman of Sears Holdings; Paul and Maurice Marciano, the founders and co-chairmen of the Guess clothing company; Gary C. Wendt, the former General Electric and Conseco executive; and Bill Simon Jr., who ran for governor of California in 2002.
The investors are clients of Presidio, a firm that sold the tax shelters to allow investors to shield billions of dollars in income and that has gone to court to defend those shelters. Presidio, which worked with the accounting firm KPMG and which maintains that the tax shelter is legal, is seeking to force the I.R.S. to disclose the internal deliberations and legal reasoning behind its decision to ban the tax shelter.