Prati v. United States

Opinion and Order

BLOCK, Judge.

This action is representative of 77 factually-similar, so-called “AMCOR” partnership tax refund cases, which are consolidated for the purposes of the instant motions. These partnerships comprised part of a group of similarly-structured California limited partnerships that were marketed and managed by American Agri-Corp., Inc. (“AMCOR”). Beginning in 2001, 129 AMCOR tax refund cases were filed in the U.S. Court of Federal Claims, of which 124 were transferred to this judge for administrative convenience and efficiency reasons by request of the parties.1 Of the 124…