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McGOWAN v. UNITED STATES

CASE NO. 3:19 CV 1073.

694 F.Supp.3d 992 (2023)

Dr. Peter E. MCGOWAN, et al., Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Ohio, Western Division.

Filed September 25, 2023.

Attorney(s) appearing for the Case

Samuel J. Lauricia, III, Scott J. Orille, Walter A. Scott Lucas, Matthew C. Miller, Weston Hurd, Cleveland, OH, for Plaintiffs Dr. Peter E. McGowan, Michelle L. McGowan.

Matthew C. Miller, Samuel J. Lauricia, III, Weston Hurd, Cleveland, OH, for Plaintiff Peter E. McGowan DDS, Inc.

Aria M. Rubenstein, Edward J. Murphy, Lauren E. Hume, Stephanie Weiner Chernoff, Noah D. Glover-Ettrich, U.S. Department of Justice—Civil Division, Washington, DC, for Defendant.

MEMORANDUM OPINION AND ORDER

INTRODUCTION

In 2011, Dr. Peter E. McGowan put in place for his business a life insurance policy product known as a Restricted Property Trust. In 2016, that policy vested, and its cash value transferred to Dr. McGowan. The IRS audited Dr. McGowan's...

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