TIFD III-E INC. v. U.S.

Nos. 01cvl839 (SRU) (lead), 01cvl840 (SRU).

8 F.Supp.3d 142 (2014)

TIFD III-E INC., The Tax Matters Partner of Castle Harbour-I Limited-Liability Company, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Connecticut.

Signed March 28, 2014.


Attorney(s) appearing for the Case

Ann H. Rubin , Carmody & Torrance, Waterbury, CT, Anthony M. Fitzgerald , David S. Hardy , Carmody & Torrance, New Haven, CT, David J. Curtin , Michael J. Desmond, William S. McKee , William F. Nelson , Bingham McCutchen , John A. Galotto , McKee & Nelson, Washington, DC, Suzanne C. Feese , King & Spalding, Atlanta, GA, for Plaintiff.

Christine Grant Michaelis , Lara E. Ewens , Robert J. Higgins , Barry E. Reiferson , U.S. Department of Justice, Washington, DC, John B. Hughes , U.S. Attorney's Office, New Haven, CT, for Defendant.


RULING ON MOTION FOR IPOSITION OF THE NELIGENCE PENALTY

STEFAN R. UNDERHILL, District Judge.

Defendant, the United States, moves for an order imposing a negligence penalty on plaintiff TIFD III-E Inc. ("TIFD") for tax years 1997 and 1998. During the 1990s, TIFD's parent company, General Electric Capital Corporation ("GECC"), joined with a pair of Dutch banks ("the Dutch Banks" or "the Banks") to form an aircraft leasing company. TIFD considered the...

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