Legal Opinion

Houston Industries Inc. v. United States

United States Court of Federal Claims

Decided October 11, 1994No. 91-1570TPublishedCited by 8 opinions

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

  1. Helvering v. CliffordSupreme Court of the United States · 1940
  2. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  3. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  4. James v. United StatesSupreme Court of the United States · 1961
  5. Commissioner v. Indianapolis Power & Light Co.Supreme Court of the United States · 1990

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3Cited by8 opinions

  1. Cencast Services, L.P. v. United StatesUnited States Court of Federal Claims · 2010
  2. Dominion Resources, Inc. v. United StatesDistrict Court, E.D. Virginia · 1999
  3. Houston Industries Incorporated and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 1997
  4. Herbel v. CommissionerUnited States Tax Court · 1996
  5. Inductotherm Industries, Inc. v. United StatesCourt of Appeals for the Third Circuit · 2003

3 more not listed; retrieve them via the Exa API.

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