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RUSSIAN RECOVERY FUND LTD. v. U.S.

2016-1718, 2016-1719 2016-1719.

851 F.3d 1253 (2017)

RUSSIAN RECOVERY FUND LIMITED, Plaintiff-Appellant v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided: March 14, 2017.

Attorney(s) appearing for the Case

DOUGLAS HALLWARD-DRIEMEIER , Ropes & Gray LLP, Washington, DC, argued for plaintiff-appellant. Also represented by COURTNEY M. COX , JUSTIN FLORENCE , KATHLEEN SAUNDERS GREGOR , LORETTA R. RICHARD , Boston, MA; BRITTANY CVETANOVICH , Chicago, IL.

ANDREW M. WEINER , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by RICHARD FARBER , GILBERT STEVEN ROTHENBERG , CAROLINE D. CIRAOLO , DIANA L. ERBSEN .

Before O'Malley, Bryson, and Wallach, Circuit Judges.

Appellant Russian Recovery Fund Limited ("RRF"), acting through its tax matters partners Russian Recovery Advisers, L.L.C. ("RRA") and Bracebridge Capital, L.L.C. ("Bracebridge"), sued the United States ("the Government") in the U.S. Court of Federal Claims, seeking readjustment of partnership items pursuant to the Tax Equity...

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