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TIFD III-E INC. v. U.S.

Nos. CIV.A. 3:01CV1839(SRU), CIV.A. 3:01CV1840(SRU).

342 F.Supp.2d 94 (2004)

TIFD III-E INC., the Tax Matters Partner of Castle Harbour-I Limited-Liability Company, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Connecticut.

November 1, 2004.

Attorney(s) appearing for the Case

Anthony M. Fitzgerald, Carmody & Torrance, New Haven, CT, Suzanne C. Feese, King & Spalding, Atlanta, GA, David J. Curtin, John A. Galotto, William F. Nelson, Michael J. Desmond, William S. McKee, McKee & Nelson, Washington, DC, for Plaintiff.

John B. Hughes, U.S. Attorney's Office, New Haven, CT, Lara E. Ewens, Christine Grant Michaelis, Tax Division, Robert J. Higgins, U.S. Department of Justice Tax Division, Washington, DC, for Defendant.

MEMORANDUM OF DECISION

UNDERHILL, District Judge.

TIFD III-E Inc. ("TIFD III-E") has sued the United States of America to recover approximately $62 million that TIFD III-E deposited with the Internal Revenue Service ("I.R.S.") in satisfaction of an alleged tax liability. That tax liability arose from the I.R.S.'s determination that TIFD III-E had incorrectly calculated and reported the amount of income TIFD III-E earned as a partner in Castle Harbour...

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