Legal Opinion
Tifd Iii-E Inc. v. United States
District Court, D. Connecticut
Decided November 1, 2004No. CIV.A. 3:01CV1839(SRU), CIV.A. 3:01CV1840(SRU)PublishedCited by 8 opinions
1Opinion of the Court
MEMORANDUM OF DECISION
UNDERHILL, District Judge.
TIFD III-E Inc. (“TIFD III-E”) has sued the United States of America to recover approximately $62 million that TIFD III-E deposited with the Internal Revenue Service (“I.R.S.”) in satisfaction of an alleged tax liability. That tax liability arose from the I.R.S.’s determination that TIFD III-E had incorrectly calculated and reported the amount of income TIFD III-E earned as a partner in Castle Harbour-I Limited-Liability Company (“Castle Har-bour”). The case was tried to the court over eight days. The court’s findings of fact and conclusions of…
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Asa Investerings Partnership,appellants v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 2000
8 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
- Tifd Iii-E, Inc. v. United States of America, Docket No. 05-0064-CvCourt of Appeals for the Second Circuit · 2006
- Bank of New York Mellon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2015
- Altria Group, Inc. v. United StatesDistrict Court, S.D. New York · 2010
- Tifd Iii-E, Inc. v. United StatesCourt of Appeals for the Second Circuit · 2012
3 more not listed; retrieve them via the Exa API.