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HIGHLAND CAPITAL MANAGEMENT, L.P. v. U.S.

No. 14-mc-0174-P1 (CM).

51 F.Supp.3d 544 (2014)

HIGHLAND CAPITAL MANAGEMENT, L.P., Petitioner, v. UNITED STATES of America, Respondent.

United States District Court, S.D. New York.

Signed October 9, 2014.

Attorney(s) appearing for the Case

Gabrielle Elise Farina, William Mayer Katz, Jr., Thompson & Knight, LLP, New York, NY, Mary A. McNulty, Thompson & Knight LLP, Dallas, TX, for Petitioner.

Shane Patrick Cargo, U.S. Attorney Office, New York, NY, for Respondent.

MEMORANDUM DECISION AND ORDER ENFORCING SUMMONS

Petitioner Highland Capital Management, L.P. ("Highland" or "the taxpayer"), a Texas-based hedge fund, brings this proceeding to quash a third party summons served on Barclays Bank PLC ("Barclays") by the Internal Revenue Service ("IRS") in connection with an audit...

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