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MAS ONE LIMITED PARTNERSHIP v. U.S.

No. 03-4188.

390 F.3d 427 (2004)

MAS ONE LIMITED PARTNERSHIP, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: November 19, 2004.

Attorney(s) appearing for the Case

ARGUED: Terrence A. Grady, Terrence A. Grady & Associates Co., Columbus, Ohio, for Appellant. Teresa E. McLaughlin, Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Terrence A. Grady, Terrence A. Grady & Associates Co., Columbus, Ohio, for Appellant. Teresa E. McLaughlin, Joel L. McElvain, Department of Justice, Washington, D.C., for Appellee.

Before: KENNEDY and GILMAN, Circuit Judges; HOOD, District Judge.

OPINION

GILMAN, Circuit Judge.

Mas One Limited Partnership borrowed $14.5 million in order to build an office building in Clearwater, Florida. Five years later, Mas One's sole limited partner abandoned its interest in the partnership and paid the remaining principal balance of the loan in order to obtain a release from its Debt Service Guaranty Agreement. Mas One listed this payment on its federal income tax...

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