Washington Mutual, Inc. v. United States

OPINION

ENGLAND, District Judge:

Plaintiff-Appellant Washington Mutual, Inc. (“Appellant”), as successor in interest to H.F. Ahmanson & Co., and Ahman-son’s wholly owned subsidiary Home Savings of America (“Home”), appeals from a judgment entered in favor of Defendant-Appellee United States of America (“Government”) after a bench trial in this tax refund action. Appellant argued in the district court that it was entitled to refunds attributable to losses and deductions it should have been afforded for certain intangible assets acquired during the savings and loan crisis of the 1970s and 1980s.…