Legal Opinion

McGowan v. United States

District Court, N.D. Ohio

Decided September 25, 2023No. 3:19-cv-01073Unknown

1Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION DR. PETER E. MCGOWAN, et al., CASE NO. 3:19 CV 1073 Plaintiffs, v. JUDGE JAMES R. KNEPP II UNITED STATES OF AMERICA, MEMORANDUM OPINION AND Defendant. ORDER INTRODUCTION In 2011, Dr. Peter E. McGowan put in place for his business a life insurance policy product known as a Restricted Property Trust. In 2016, that policy vested, and its cash value transferred to Dr. McGowan. The IRS audited Dr. McGowan’s business, concluded it had incorrectly claimed deductions, and imposed additional tax and penalties…

2Cases cited8 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
  3. Kerry W. Illes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
  4. In Re FirstEnergy Corp. Securities LitigationDistrict Court, N.D. Ohio · 2004
  5. United States v. Michael HenryCourt of Appeals for the Sixth Circuit · 2020

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