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

Civil Action Nos. 3:01cv1839 (SRU) (lead), 3:01cv1840 (SRU).

660 F.Supp.2d 367 (2009)

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.

As Amended October 23, 2009.


Attorney(s) appearing for the Case

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

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


MEMORANDUM OF DECISION

STEFAN R. UNDERHILL, District Judge.

In 2001, TIFD III-E Inc. ("TIFD III-E") 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...

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