Legal Opinion
TIFD III-E Inc. v. United States
District Court, D. Connecticut
Decided March 28, 2014No. Nos. 01cv1839 (SRU) (lead), 01cv1840 (SRU)PublishedCited by 3 opinions
1Opinion of the Court
RULING ON MOTION FOR IMPOSITION OF THE NEGLIGENCE PENALTY
STEFAN R. UNDERHILL, District Judge.
Defendant, the United States, moves for an order imposing a negligence penalty on plaintiff TIFD III-E Inc. (“TIFD”) for tax years 1997 and 1998. During the 1990s, TIFD’s parent company, General Electric Capital Corporation (“GECC”), joined with a pair of Dutch banks (“the Dutch Banks” or “the Banks”) to form an aircraft leasing company. TIFD considered the Dutch Banks to be its partners in the venture, and did not report any income allocated to the Banks on its own tax returns. During the course of…
2Cases cited19 opinions
- Stobie Creek Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2010
- Commissioner of Internal Revenue v. OPP Holding Corp.Court of Appeals for the Second Circuit · 1935
- Glenn A. Mortensen v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- Jewel Tea Co. v. United StatesCourt of Appeals for the Second Circuit · 1937
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3Cited by3 opinions
- Salem Financial, Inc. Ex Rel. Branch Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2015
- Wells Fargo & Company v. United StatesCourt of Appeals for the Eighth Circuit · 2020
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2015