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SILVER v. I.R.S.

Civil No. 19-cv-247 (APM).

531 F.Supp.3d 346 (2021)

Monte SILVER, et al., Plaintiffs, v. INTERNAL REVENUE SERVICE, et al., Defendants.

United States District Court, District of Columbia.

Signed March 28, 2021.

Attorney(s) appearing for the Case

Lawrence Marc Zell, Zell, Aron & Co., Israel, for Plaintiffs Monte Silver, Monte Silver, Ltd.

Joseph A. Sergi, Nishant Kumar, U.S. Department of Justice, Tax Division, Washington, DC, for Defendants.

MEMORANDUM OPINION

I. INTRODUCTION

As part of the Tax Cut and Jobs Act of 2017, Congress amended Internal Revenue Code ("IRC") section 965 to impose a one-time "transition tax" on U.S. shareholders of certain specified foreign corporations based on the...

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