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KOHLER CO. v. U.S.

No. 01-C-753.

387 F.Supp.2d 921 (2005)

KOHLER COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Wisconsin.

September 1, 2005.

Attorney(s) appearing for the Case

Philip Karter and Herbert Odell, Miller & Chevalier Chartered, Bala Cynwyd, PA, Adam Feinberg, Miller & Chevalier Chartered, Washington, DC, for Plaintiff.

Andrew T. Pribe and Hilarie E Snyder, United States Department of Justice Tax Division, Washington, DC, for Defendant.

DECISION AND ORDER

GRIESBACH, District Judge.

The Kohler Company has once again moved for summary judgment, reprising one of the questions addressed in a previous decision and order issued February 20, 2003. In particular, Kohler asks me to rule that the value of the pesos received by a Kohler subsidiary in a 1987 debt equity swap transaction cannot be proven with any reliability. If that is the case, Kohler then argues that I must apply a presumption that...

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