The U.S. District Court in Massachusetts yesterday sided with the IRS in a 357-page opinion and disallowed two tax shelters used by the EMC Corp. founder (and ambassador to Ireland under President George W. Bush) RIchard J. Egan and his wife generating $160 million of ordinary losses and $167 million of capital losses.  Fidelity International Currency Advisor A Fund LLC v. United States (D. MA May, 17, 2010).  From Bloomberg, EMC Founder Egan Cheated IRS While Ireland Envoy, Judge Says, by Ryan J. Donmoyer & Jef Feeley:

EMC Corp. founder Richard J. Egan used a sham tax shelter to cheat the U.S. government out of more than $62 million starting the same year former President George W. Bush named him ambassador to Ireland, a federal judge ruled.

Egan, who died Aug. 29, used a variation of a widely used transaction known as “Son of Boss” to avoid paying capital gains taxes on more than $327 million in gains from stock or options in Boston-based EMC, the world’s biggest maker of storage computers, according to court papers.

In a 357-page decision, U.S. District Judge Dennis Saylor in Boston ruled yesterday that Egan and his wife, Maureen, concocted transactions with offshore entities to generate artificial tax losses intended to wipe out his taxable gains. The Egans were aided by nine advisers, including law firms and accountants, Saylor wrote. The transactions were managed by their son, Michael J. Egan, the judge said.