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NEUBERGER, QUINN, GIELEN, RUBIN & GIBBER v. U.S.

2:12mc351 & 2:12mc352.

183 F.Supp.3d 752 (2016)

NEUBERGER, QUINN, GIELEN, RUBIN & GIBBER, P.A., Petitioner, v. UNITED STATES of America, Respondent.

United States District Court, W.D. Pennsylvania.

Signed April 21, 2016.

Attorney(s) appearing for the Case

Thomas J. Farrell, Jennifer M. Stanley, Farrell & Reisinger LLC, Pittsburgh, PA, Paul B. Hynes, Jr., Paula M. Junghans, Zuckerman Spaeder LLP, Washington, DC, for Petitioner.

Charles M. Flesch, Geoffrey J. Klimas, Andrew C. Strelka, Department of Justice, Washington, DC, Paul E. Skirtich, United States Attorney's Office, Pittsburgh, PA, for Respondent.

MEMORANDUM OPINION

I. INTRODUCTION

The Internal Revenue Service (the "IRS") is examining two limited liability companies, SL Zeta Health LLC ("SLZ") and Zeta Health Investors LLC ("ZHI"), who filed tax returns claiming millions of dollars in income tax losses for 2009 and 2010...

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