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NCBA/NCE v. U.S.

Civ. A. No. 89-M-1912.

843 F.Supp. 655 (1993)

NATIONAL COMMODITY AND BARTER ASSOCIATION/NATIONAL COMMODITY EXCHANGE, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Colorado.

October 22, 1993.

Attorney(s) appearing for the Case

William A. Cohan, Jennifer A. Greene, Cohan & Greene, Encinitas, CA, for plaintiff.

Seth G. Heald, Office of Special Litigation, Tax Div., U.S. Dept. of Justice, Washington, DC, William G. Pharo, Asst. U.S. Atty., Denver, CO, for defendant.

MEMORANDUM OPINION AND ORDER

MATSCH, District Judge.

The National Commodity and Barter Association/National Commodity Exchange (NCBA/NCE) brings this suit against the United States for a refund of penalties assessed under I.R.C. § 6698 for failing to file partnership returns for the years 1979-1988 and I.R.C. § 6700 for promoting an abusive tax shelter. This court has jurisdiction over the matter pursuant to I.R.C. § 7422 and 28 U.S.C. §...

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