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NORTH CENTRAL RENTAL & LEASING, LLC v. U.S.

No. 13-3411.

779 F.3d 738 (2015)

NORTH CENTRAL RENTAL & LEASING, LLC, by and through its Tax Matters Partner, M. Daniel BUTLER, Plaintiff-Appellant v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: March 2, 2015.

Attorney(s) appearing for the Case

Thomas Carl Borders , argued, Chicago, IL ( Gregory Palmer and Katharine O'Connor , on the brief), for appellant.

Jennifer Marie Rubin , argued, Washington, DC ( Jennifer Marie Rubin , on the brief), for appellee.

Before MURPHY, SMITH, and GRUENDER, Circuit Judges.

The Internal Revenue Service (IRS) determined that North Central Rental & Leasing, LLC ("North Central") had improperly claimed "nonrecognition treatment"1 of gains from certain property exchanges. North Central filed suit against the United States, seeking a determination that its gains from...

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