LEVAL, Circuit Judge.
This appeal tests the power of the Internal Revenue Service to examine and recharacterize an interest which accords with its ostensible classification only in illusory or insignificant respects. The taxpayer-plaintiff TIFD III-E, Inc. (the "taxpayer" or "TIFD III-E"), a subsidiary of General Electric Capital Corporation ("GECC"), brought suit in the United States District Court for the District of Connecticut (Stefan R. Underhill, J.)...
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