Schaeffler v. United States of America
Georg F.W. Schaeffler, INA-Holding Schaeffler GmbH & Co. KG, Schaeffler Holding GmbH & Co. KG and Schaeffler Holding, LP |
United States of America |
1:2013cv04864 |
July 12, 2013 |
US District Court for the Southern District of New York |
Foley Square Office |
XX Out of State |
Harold Baer |
Tax Suits: IRS-Third Party |
26 U.S.C. ยง 7609 IRS: Petition to Quash IRS Summons |
None |
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Filing 81 OPINION AND ORDER. For the foregoing reasons, the respondent's motion to dismiss (Docket #73) is granted and the petitioners' motion for entry of a judgment (Docket #76) is denied. The Clerk is requested to enter judgment dismissing this pe tition for lack of subject matter jurisdiction and to close this case. re: 76 MOTION for Judgment Granting Amended Petition to Quash Summons filed by Schaeffler Holding GmbH & Co. KG, INA-Holding Schaeffler GmbH & Co. KG, Schaeffler Holding, LP, Georg F.W. Schaeffler, 73 MOTION to Dismiss the Amended Petition filed by United States of America. (Signed by Magistrate Judge Gabriel W. Gorenstein on 7/16/2016) (rjm) |
Filing 54 OPINION AND ORDER: For these reasons, we find that the EY Tax Memo, as well as the related responsive documents, would have been produced in the same form irrespective of any concern about litigation. Accordingly, these documents are not protected from disclosure under the work product doctrine. For the foregoing reasons, we deny the petition to quash. SO ORDERED. (Signed by Magistrate Judge Gabriel W. Gorenstein on 5/28/2014) (ama) |
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