Consolidated Edison Co. v. United States

OPINION

HORN, Judge.

FINDINGS OF FACT

The plaintiff, Consolidated Edison Company of New York, Inc. (Con Ed), and its subsidiaries, brought this claim to recover funds allegedly overpaid to the Internal Revenue Service (IRS) for the 1997 tax year, *232when the IRS disallowed certain rental, interest and transaction cost deductions taken by the plaintiff, associated with a leveraged lease transaction the plaintiff entered into in 1997. This complex, leveraged lease transaction, referred to in a number of ways by the parties, including “leveraged lease,” “lease-leaseback,” or “lease-in, lease-out,”…