AWG LEASING TRUST v. U.S.

Case No. 1:07-CV-857.

592 F.Supp.2d 953 (2008)

AWG LEASING TRUST, KSP Investments, Inc. As Tax Matters Partner, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Ohio.

May 28, 2008.


Attorney(s) appearing for the Case

Brian J. Lamb, David J. Hooker, James D. Robenalt, Jeffry J. Erney, Anthony J. Rospert, Frank R. Desantis, Michele Kryszak Abraham, Stephen D. Williger, Thompson Hine, Cleveland, OH, Tracy A. Hannan, Thompson Hine, Atlanta, GA, for Plaintiff.

Karen A. Smith, Matthew Von Schuch, Robert J. Kovacev, Stuart J. Bassin, U.S. Department of Justice, Washington, DC, for Defendant.


OPINION & ORDER

[Resolving Doc. No. 1]

JAMES S. GWIN, District Judge:

I. Introduction1

With this action, two large national banks dispute adjustments that the Internal Revenue Service ("IRS") made to partnership federal income tax returns for the 1999, 2000, 2001, 2002, and 2003 tax years. In those adjustments, the IRS found that the banks' partnership, the AWG Leasing Trust, mis-characterized a...

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