Legal Opinion
Gss Holdings (Liberty) Inc. v. United States
United States Court of Federal Claims
Decided July 26, 2021No. 19-728Published
1Opinion of the Court
In the United States Court of Federal Claims No. 19-728T (Filed: July 26, 2021) ****************** ** GSS HOLDINGS (LIBERTY) INC., Tax refund suit; I.RC. § Plaintiff, 707(b)(1); I.R.C. § 165; Related party transaction; Substance v. over form; Step transaction doctrine; Danielson rule. THE UNITED STATES, Defendant. ********************* Brian W. Kittle, New York, NY, with whom was James B. Kelly, for plaintiff. Dara B. Oliphant, Trial Attorney, United States Department of Justice, Tax Division, Washington, DC, with whom were David A. Hubbert, Acting Assistant Attorney General, David I. Pincus,…
2Cases cited12 opinions
- The Black & Decker Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 2006
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Commissioner v. ClarkSupreme Court of the United States · 1989
- King Enterprises, Inc. v. The United StatesUnited States Court of Claims · 1969
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
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