Houston Industries Inc. v. United States
United States Court of Federal Claims
1Opinion of the Court
OPINION
BRUGGINK, Judge.
This action, brought pursuant to the Tucker Act, 28 U.S.C. § 1491 (1988), and section 7422 of the Internal Revenue Code (“IRC”) of 1986, as amended, 26 U.S.C. § 1 et seq. (1986), is before the court on the parties’ cross-motions for partial summary judgment. After considering the written and oral arguments, the court concludes that the plaintiff’s motion should be granted and the defendant’s motion should be denied.
FACTUAL BACKGROUND
Plaintiff, Houston Industries Incorporated and Subsidiaries (“HU”), operates a public utility, Houston Lighting and Power Company (“HL &…
2Cases cited17 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- James v. United StatesSupreme Court of the United States · 1961
- Commissioner v. Indianapolis Power & Light Co.Supreme Court of the United States · 1990
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- Houston Industries Incorporated and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 1997
- Herbel v. CommissionerUnited States Tax Court · 1996
- Inductotherm Industries, Inc. v. United StatesCourt of Appeals for the Third Circuit · 2003
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