The U.S. government on Monday sued Deutsche Bank AG (DBKGn.DE), seeking to recoup greater than $190 million from the German bank over supposed tax fraud greater than 14 years ago.

According to a complaint filed in the U.S. District Court in Manhattan, Deutsche Bank used "insolvent" shell companies to carry out a series of fraudulent conveyances designed to hide taxable gains from the U.S. Internal Revenue Service.

UNITED STATE Attorney Preet Bharara said the case arose from Deutsche Bank's late 1999 purchase of a corporation that was sitting on an unrealized $150 million gain in shares of medicine maker Bristol-Myers Squibb Co (BMY.N).

The government said that to avoid a potential $51million of federal income taxes on the gain, Deutsche Bank in 2000 sold the stock for below fair value to the covering companies, which paid for them with short-term loans.

These shell companies in turn sold the stock to a various Deutsche Bank entity, causing the tax obligation responsibility, just to then repay the loans, leaving them without funds to pay taxes.

‘Through fraudulent conveyances involving shell companies, Deutsche Bank tried to make its prospective tax liabilities disappear,’ Bharara said in a statement. ‘This was nothing more than a shell game.’

The $190 million sought includes the alleged unpaid taxes, interest & penalties.

In a statement, Deutsche Bank spokeswoman Renee Calabro said the bank ‘completely addressed ‘the concern in a 2009 arrangement with the IRS, where the government had ‘Abandoned’ the theory that the Bank was responsible for the taxes.

‘While it is not clear to us why we are being pursued again for the very same tax obligations, we intend to again defend intensely against these claims,’ she said.

Wells Fargo Bank NA (WFC.N), whose precursor First Union National Bank was trustee for a count on set up for the transactions, was additionally named as a defendant during that capability. A spokesman, Ancel Martinez, decreased to comment.