Legal Opinion
McGann v. United States
United States Court of Federal Claims
Decided April 25, 2008No. 05-1189TPublishedCited by 4 opinions
1Opinion of the Court
OPINION AND ORDER
LETTOW, Judge.
The plaintiffs in this case, Thomas and Evelyn McGann, seek a refund of enhanced interest they paid under former 26 U.S.C. [I.R.C.] § 6621(c), a repealed provision that was applicable to “tax motivated transactions” (“TMTs”). The interest was assessed by the Internal Revenue Service (“IRS,” “the Service,” or “the government”) after the conclusion of proceedings before the United States Tax Court involving a partnership in which Mr. McGann was an indirect partner. The interest rate applied was 120 percent of *643the regular underpayment rate as provided by former…
2Cases cited31 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
- Mingus Constructors, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- United States v. Clintwood Elkhorn Mining Co.Supreme Court of the United States · 2008
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3Cited by4 opinions
- Marriott International Resorts, L.P. v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Prati v. United StatesUnited States Court of Federal Claims · 2008
- Marriott International Resorts, L.P. v. United StatesUnited States Court of Federal Claims · 2008
- Bush v. United StatesUnited States Court of Federal Claims · 2011