Legal Opinion
Brown & Williamson, Ltd. v. United States
United States Court of Claims
Decided August 26, 1982No. 39-81TPublishedCited by 28 opinions
1Opinion of the CourtFriedman, Chief Judge
Following a retroactive reduction of taxes by an income tax treaty, the plaintiff received a refund of taxes it had paid for four years before the effective date of the treaty. The question in this case, which is before us on cross-motions for summary judgment, is whether the plaintiff is entitled to interest on the refunds from the original date of payment of the taxes (as the plaintiff contends) or only from the effective date of the treaty (as the government argues). We hold for the plaintiff.
I
The plaintiff is a British corporation. In the years 1975 to 1978, the plaintiffs American…
2Cases cited14 opinions
- Billings v. United StatesSupreme Court of the United States · 1914
- United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
- Rodgers v. United StatesSupreme Court of the United States · 1947
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Commissioner v. KowalskiSupreme Court of the United States · 1977
9 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Skillo v. United StatesUnited States Court of Federal Claims · 2005
- Xerox Corporation v. United StatesCourt of Appeals for the Federal Circuit · 1995
- Buser v. United StatesUnited States Court of Federal Claims · 2009
- Columbia Marine Services, Inc., Individually and on Behalf of a Class of Similarly Situated v. Reffet Limited, a United Kingdom CorporationCourt of Appeals for the Second Circuit · 1988
- Gluck v. United StatesUnited States Court of Federal Claims · 2008
23 more not listed; retrieve them via the Exa API.