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Germany’s Deutsche Bank dodged over $100 million in federal taxes, according to allegations in a lawsuit filed by the U.S. Attorney’s office in the Southern District of New York Monday afternoon.

“Through fraudulent conveyances involving shell companies, Deutsche Bank tried to make its potential tax liabilities disappear. This was nothing more than a shell game,” said Manhattan U.S. Attorney Preet Bharara.

The lawsuit alleges that Deutsche Bank used three underfunded shell companies in the spring of 2000 to intentionally avoid the tax liabilities on appreciated stock.

The U.S. seeks to recoup more than $190 million in taxes, penalties and interest.

In a statement, Deutsche Bank said “we fully addressed the government’s concerns about this 14-year old transaction in a 2009 agreement with the IRS. In connection with that agreement they abandoned their theory that DB was liable for these taxes, and while it is not clear to us why we are being pursued again for the same taxes, we plan to again defend vigorously against these claims.”

Wells Fargo was named in the lawsuit as a trustee to one of the shell companies.

Shares of Deutsche Bank slid 2.5% to $32 on the news and are down 25% for the year.

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