Cencast Services, L.P. v. United States

OPINION AND ORDER

GEORGE W. MILLER, Judge.

These consolidated tax refund cases1 are before the Court on plaintiffs’ Motion for Summary Judgment and defendant’s Motion for Partial Summary Judgment. For the following reasons, plaintiffs’ motion for summary judgment is DENIED, and defendant’s motion for partial summary judgment is GRANTED.

Introduction

This case concerns plaintiffs’ efforts to arrange their affairs, and the affairs of their *160clients, in order to minimize their liability to pay certain taxes.2 In order to understand these efforts, it is helpful to review the types of taxes at issue in…