Washington Mutual, Inc. v. United States

MEMORANDUM OPINION AND ORDER

BARBARA JACOBS ROTHSTEIN, District Judge.

I. INTRODUCTION

Plaintiff Washington Mutual, Inc. (“Plaintiff’), as successor in interest to *1097Home Savings of America, FSB (“Home”), brought this tax refund suit to recover taxes assessed by the Internal Revenue Service (“IRS”) with respect to the 1990, 1992, and 1993 tax years. This case represents a chapter in a continuing saga that has its genesis in the savings and loan crisis of the late 1970’s and early 1980’s. Since that time, numerous lawsuits involving Home and other similarly situated litigants have wound their way…