Legal Opinion

Gingerich v. United States

United States Court of Federal Claims

Decided August 24, 2007No. Nos. 98-533T, 98-5330T to 98-5350TPublishedCited by 1 opinion

1Opinion of the Court

OPINION AND ORDER FOR FINAL JUDGMENT

LETTOW, Judge.

Settling the final judgment in these consolidated cases requires resolution of an issue of statutory construction that apparently is one of first impression. After conducting trial in these 22 consolidated cases, this court, in a prior decision, determined that the Internal Revenue Service (“IRS” or “government”) did not assess the plaintiffs with additional tax within the time prescribed by Congress after a settlement was entered concerning a partnership item. Gingerich v. United States, 77 Fed.Cl. 231 (2007) (“Gingerich III”). By that…

2Cases cited27 opinions

  1. John R. Sand & Gravel Company v. United StatesCourt of Appeals for the Federal Circuit · 2006
  2. Robert Demartino, Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Appellee-Cross-AppellantCourt of Appeals for the Second Circuit · 1988
  3. BRADFORD-WHITE CORPORATION, Appellant in 88-1781 v. ERNST & WHINNEY; BRADFORD-WHITE CORPORATION, v. ERNST & WHINNEY, Appellant in 88-1828Court of Appeals for the Third Circuit · 1989
  4. GAF Corp. v. CommissionerUnited States Tax Court · 2000
  5. Shell Petroleum, Inc., and Subsidiary Corporations v. United StatesCourt of Appeals for the Third Circuit · 1999

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3Cited by1 opinion

  1. Litman v. United StatesUnited States Court of Federal Claims · 2008

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