Legal Opinion
Fennell v. United States
District Court, D. Colorado
Decided June 30, 1993No. Civ. A. No. 92-F-1646PublishedCited by 2 opinions
1Opinion of the Court
ORDER REGARDING MOTIONS FOR SUMMARY JUDGMENT
SHERMAN G. FINESILVER, Chief Judge.
This case involves a claim for refund of taxes paid to the Internal Revenue Service (“IRS”). Jurisdiction is based on 28 U.S.C. § 1346(a)(1). This matter comes before the Court on Plaintiffs’ and Defendant’s cross-motions for summary judgment pursuant to Fed.R.Civ.P. 56(c). The relevant facts are undisputed and the issues of law have been fully briefed. For the reasons stated below, the Court finds in favor of Defendant.
I. BACKGROUND1
A Colorado partnership named Springhill Plaza Partnership No. 1 (“Springhill”) was…
2Cases cited12 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
- Fed. Sec. L. Rep. P 93,309 Karen A. McVay v. Western Plains Service CorporationCourt of Appeals for the Tenth Circuit · 1987
- Mountain Fuel Supply, a Utah Corporation, and Cna Insurance Company v. Reliance Insurance CompanyCourt of Appeals for the Tenth Circuit · 1991
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3Cited by2 opinions
- Slovacek v. United StatesUnited States Court of Federal Claims · 1996
- Fennell v. United StatesCourt of Appeals for the Tenth Circuit · 1994