United States Seventh Circuit

Summary judgment for plaintiff, manufacturer of plumbing products, in its suit against the government for a refund of federal income taxes is affirmed where the IRS presented no evidence that could have persuaded a rational factfinder that pesos plaintiff got from the Mexican government in exchange for a debt it surrendered were worth $19.5 million for taxable income purposes, and it suggested no alternative valuation.

Appellate Information

• Decided 11/20/2006
• Published 11/20/2006

Judges

• POSNER, Circuit Judge., Before POSNER, MANION, and WILLIAMS, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

• For Appellees:
  
• Janice A. Rhodes, Kravit, Hovel, Krawczyk & Leverson, Milwaukee, WI, Philip Karter (argued), Herbert Odell, Miller & Chevalier, West Conshohocken, PA, for Plaintiff-Appellee., Bruce R. Ellisen, Bridget M. Rowan (argued), Dept. of Justice, Tax Division, Appellate Section, Washington, DC, for Defendant-Appellant.