Doyon, Ltd. v. United States

OPINION

REGINALD W. GIBSON, Senior Judge:

INTRODUCTION

This tax refund case is pending before the court following a trial on the merits, respecting the second of three counts averred in plaintiffs complaint,1 held in Washington, D. C., on December 1, 1997. Doyon, Limited (Doyon or plaintiff) seeks a refund of alternative minimum tax (AMT) and environmental tax allegedly overpaid for its taxable year ended October 31, 1988, in the sum of $319,-409,2 plus interest as allowed by law. Doyon alleges that the Internal Revenue Service erroneously failed to apply Treas. Reg. § 1.56-l(d)(6) so as to…