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Sutherland Assists Nortel in Tax Victory Against IRS

May 8, 2001

ATLANTA (May 8, 2001) – Sutherland Asbill & Brennan LLP is pleased to announce a complete victory for our client, Nortel Networks Corp., in a four-year-old suit against the Internal Revenue Service. The IRS had asserted that Nortel owed more than $500 million for several years from the 1980's. At issue was the proper tax treatment of telecommunications equipment leasing transactions in which Nortel manufactured systems that its subsidiary then leased to customers. The U.S. Tax Court agreed with Nortel's position that these transactions did not give rise to immediately taxable sales.

Tax partner N. Jerold Cohen represented Nortel in the suit and said the decision will be a relief to manufacturers and leasing companies that use financial services subsidiaries to lease equipment: "Had we lost, there would have been a lot of leasing companies and manufacturers that would be very much worried."

Mr. Cohen's practice includes representing U.S. and foreign clients in all aspects of domestic and international tax planning and controversy matters. He has successfully litigated a number of significant federal tax cases and has handled numerous matters before the Internal Revenue Service and the Treasury Department.

Sutherland Asbill & Brennan LLP, a national law firm, has one of the largest and most highly regarded tax practice groups in the country, employing more than 70 lawyers engaged specifically in the practice of tax law. Founded in 1924, the firm has grown to more than 325 lawyers with offices in Atlanta, Austin, New York, Tallahassee and Washington.

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