AmerGen Energy Co. v. United States

94 Fed. Cl. 413 (2010)

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AmerGen Energy Co. v. United States

United States Court of Federal Claims
94 Fed. Cl. 413 (2010)

Facts

AmerGen Energy Co., LLC (AmerGen) (plaintiff) sued the United States (defendant), seeking readjustment as to the tax treatment of certain liabilities associated with nuclear-power plants AmerGen owned. During the discovery phase, AmerGen sought to admit several private-letter rulings that had been issued to the sellers of the plants. AmerGen argued that the legal issues of the case were fully answered by the private-letter rulings, which, if admitted, could resolve the case on summary judgment.

Rule of Law

Issue

Holding and Reasoning (Bush, J.)

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