Amergen Energy Co. v. United States

OPINION AND ORDER

Bush, Judge.

This ease is before the court on cross-motions for summary judgment as to Counts I-IV of the complaint, filed under Rule 56 of the Rules of the United States Court of Federal Claims (RCFC). Count V, the only other count in the complaint, has been the subject of successful settlement negotiations. For the reasons stated below, defendant’s motion for summary judgment is granted and plaintiffs motion for summary judgment is denied.

BACKGROUND

I. Relevant Facts

A. Overview

This is a readjustment of partnership items case under the Tax Equity and Fiscal Responsibility Act…