Attached Documents
- Government’s motion to exclude evidence about redesigned captive program
- Plaintiffs’ motion to exclude evidence of prior bad acts
- Plaintiffs’ motion to preclude government from taking position that contradicts IRS position in related litigation
- Plaintiffs’ motion to preclude government from using the term “tax shelter”
- Opinion and order denying expert exclusion motion
- Opinion and order denying summary judgment motions
- Plaintiffs’ summary judgment motion
- Government’s opposition to summary judgment
- Plaintiffs’ reply supporting summary judgment
- Government’s partial summary judgment motion
- Plaintiffs’ opposition to partial summary judgment
- Government’s reply supporting partial summary judgment with attachment
- Plaintiffs’ motion to exclude expert testimony with attachments
- Government’s opposition to excluding experts with attachment
- Plaintiffs’ reply supporting excluding experts
- Plaintiffs’ amended complaint
- Government’s counterclaim and answer to amended complaint