Legal Opinion
Tifd Iii-E Inc. v. United States
District Court, D. Connecticut
Decided October 23, 2009No. Civil Action 3:01cv1839 (SRU) (lead), 3:01cv1840 (SRU)PublishedCited by 4 opinions
1Opinion of the Court
MEMORANDUM OF DECISION
STEFAN R. UNDERHILL, District Judge.
In 2001, TIFD III-E Inc. (“TIFD III-E”) 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 Harbour”). After an eight-day bench trial, I ruled that: (1) Castle Harbour’s formation was…
2Cases cited29 opinions
- Pennsylvania Department of Corrections v. YeskeySupreme Court of the United States · 1998
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
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3Cited by4 opinions
- 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
- Hewlett-Packard Co. v. Comm'rUnited States Tax Court · 2012
- TIFD III-E Inc. v. United StatesDistrict Court, D. Connecticut · 2014