United States Third Circuit

In an action against the United States to recover taxes plaintiff alleges were incorrectly assessed, judgment of the district court in favor of the defendant is affirmed because: 1) subject funds were immediately taxable in full as proceeds of loans from foreign subsidiaries; and 2) plaintiff suffered no disparate treatment in comparison with another taxpayer who engaged in similar transactions but was not assessed taxes on the proceeds in the same way.

Appellate Information

• Decided 06/20/2011
• Published 06/20/2011

Judges

• Fuentes

Court

• United States Third Circuit

Counsel