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NICHOLS v. U.S.

No. 99-5580.

260 F.3d 637 (2001)

George NICHOLS, III, in his capacity as Liquidator of Kentucky Central Life Insurance Company, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: August 13, 2001.

Attorney(s) appearing for the Case

ARGUED: W. Bradford Boone, STITES & HARBISON, Lexington, Kentucky, for Appellant. Steven W. Parks, UNITED STATES DEPARTMENT OF JUSTICE, APPELLATE SECTION TAX DIVISION, Washington, D.C., for Appellee.

ON BRIEF: W. Bradford Boone, Gregory P. Parsons, STITES & HARBISON, Lexington, Kentucky, for Appellant.

Steven W. Parks, UNITED STATES DEPARTMENT OF JUSTICE, APPELLATE SECTION TAX DIVISION, Washington, D.C., for Appellee.

Before: KENNEDY, SILER, and CLAY, Circuit Judges.

Pursuant to Sixth Circuit Rule 206

OPINION

CLAY, Circuit Judge.

Plaintiff, George Nichols, III, the state-appointed liquidator for Kentucky Central Life Insurance Company ("KCL"), filed a complaint in the United States District Court for the Eastern District of Kentucky alleging that the Internal Revenue Service (IRS) owed KCL income tax refunds totaling $18,502,455 plus interest for the taxable years 1989, 1990, and 1991. Plaintiff claimed that...

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