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LOUISIANA HEALTH CARE SELF INSURANCE FUND v. U.S.

Civil Action No. 12-766.

LOUISIANA HEALTH CARE SELF INSURANCE FUND, v. THE UNITED STATES OF AMERICA.

United States District Court, M.D. Louisiana.

October 20, 2014.

Attorney(s) appearing for the Case

Louisiana Health Care Self Insurance Fund, Plaintiff, represented by David Robert Kelly , Breazeale, Sachse & Wilson, Eric Baronet Landry , Breazeale, Sachse and Wilson LLP & Van R. Mayhall, Jr. , Breazeale, Sachse & Wilson.

The United States of America, Defendant, represented by John M. Bilheimer , U.S. Department of Justice, John Joseph Gaupp , United States Attorney's Office & Steven C Woodliff , U.S. Department of Justice.

The United States of America, Counter Claimant, represented by John M. Bilheimer , U.S. Department of Justice, John Joseph Gaupp , United States Attorney's Office & Steven C Woodliff , U.S. Department of Justice.

Louisiana Health Care Self Insurance Fund, Counter Defendant, represented by David Robert Kelly , Breazeale, Sachse & Wilson, Eric Baronet Landry , Breazeale, Sachse and Wilson LLP & Van R. Mayhall, Jr. , Breazeale, Sachse & Wilson.

WRITTEN REASONS FOR DENIAL OF MOTION FOR PARTIAL SUMMARY JUDGMENT

JOHN W. deGRAVELLES, District Judge.

This matter came before the Court on the Motion for Partial Summary Judgment (R. Doc. 44) filed by plaintiff, Louisiana Health Care Self Insurance Fund ("Taxpayer"). Defendant the United States of America ("IRS") opposed the motion. After the Court ordered supplemental briefing,1 oral argument was heard...

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