Texas Instruments Incorporated, Cross-Appellant v. United States of America, Cross-Appellee

EDWIN J. HUNTER, Jr., District Judge:

This case involves claims for refund of federal income taxes in excess of $10,000,-000. The tax years involved are 1968 and 1969. Following payment of the deficiencies under protest and the disallowance of its claims for refund, plaintiff filed this suit in the District Court. There are three separate and important issues involving interpretations of Internal Revenue Code sections dealing with: (1) employer deductions to qualified employee pension trusts; (2) credit for foreign taxes paid by a Western Hemisphere Trade Corporation; and (3) the distinction…