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Sutherland secures partial summary judgment holding IRS’ assessment is untimely.

ClientK2, Inc.
Region
Florida
Description
This case involved one of the first "intermediary" transactions to be litigated. The IRS sought to impose transferee liability against our client for taxes the IRS assessed against the purchaser of our client’s operating division, which as the "intermediary" had then sold the assets to a third party. The court granted our motion for partial summary judgment holding that the IRS’ assessment against the intermediary was untimely based on the IRS’ failure to comply with TEFRA.
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