SCHALL, Circuit Judge.
Ventas, Inc. ("Ventas") is a real estate company that owns and leases hospitals, nursing centers, and personal care facilities throughout the United States. The Internal Revenue Service ("IRS") determined that it had miscalculated its alternative minimum tax ("AMT") liability and as a result had underpaid its income taxes for tax years 1990, 1991, and 1992. It therefore assessed Ventas additional income taxes for those years. Ventas paid the...
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