Santa Clara Valley Housing Group, Inc., et al. v. United States, No. 5:08-cv-05097-JF, 2011 U.S. Dist. LEXIS 107101 (N.D. Cal. Sep. 21, 2011)

(warrants issued to shareholder of closely-held, family S corporation created second class of stock which resulted in termination of S corporation status; case involves tax shelter strategy developed by KPMG known as "SC2").