Client Alert
| October 23, 2009
Taxpayer Wins LILO Case in the Court of Federal Claims
On October 21, 2009, the Court of Federal Claims found in favor of the taxpayer, Consolidated Edison Company of New York (Con Ed), holding that Con Ed was entitled to a refund for taxes with respect to previously disallowed deductions incurred in connection with a leasein, lease-out (LILO) transaction.1 This taxpayer victory comes on the heels of the very successful IRS settlement initiative that the IRS announced on August 6, 2008, for LILO and sale-in, lease-out (SILO) transactions. The IRS offered the settlement initiative after the IRS victories in three LILO/SILO cases: BB&T Corp v. United States2; AWG Leasing Trust v. United States3; and Fifth Third Bancorp v. United States.
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