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Worldwide Equipment, Inc. v. United States

Client(s): Worldwide Equipment, Inc.

Action was filed by Worldwide Equipment, Inc. (“Worldwide”) against the IRS to recover excise taxes assessed on off-road, heavy-duty, coal-hauling trucks.  Worldwide claimed that the trucks were exempt from taxes under the “off-highway” vehicle exemption.  The IRS countersued for back taxes.  The trial court granted summary judgment in favor of the IRS and Worldwide appealed.  The Sixth Circuit Court of Appeals vacated the trial court’s decision and remanded the case for further proceedings.  Shortly before trial, Worldwide filed motions in limine to exclude certain evidence, including testimony and surveys from the IRS’s purported experts.  The trial court ruled in favor of Worldwide on all its motions in limine, which led to a settlement in Worldwide’s favor.  This case settled. 

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