United States v. Tate & Lyle North American Sugars, Inc.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

BERMAN, District Judge.

I. Introduction

On or about December 10, 1997, plaintiff the United States of America (“Plaintiff’ or the “IRS” or the “Government”) commenced this action, “seek[ing] to recover a $1,526,100.60 interest payment it made to defendant Tate & Lyle North American Sugars, Inc., successor to Domino Sugar Corporation, formerly known as Amstar Sugar Corporation ..., when the [IRS] returned a remittance that Amstar sent the IRS in December 1990.” 1 PreTrial Memorandum of Law of Plaintiff United States (“Pl.Mem.”), dated April 25, 2002, at…