AWG Leasing Trust v. United States

OPINION & ORDER

[Resolving Doc. No. 1]

JAMES S. GWIN, District Judge:

I. Introduction 1

With this action, two large national banks dispute adjustments that the Internal Revenue Service (“IRS”) made to partnership federal income tax returns for the 1999, 2000, 2001, 2002, and 2003 tax years. In those adjustments, the IRS found that the banks’ partnership, the AWG Leasing Trust, mis-characterized a 1999 transaction as a $423 million purchase of a German waste-to-energy facility. The IRS says the transaction was a thinly-veiled tax dodge that attempted to skirt IRS and Congressional action directed…