Cargill, Inc. v. United States

MEMORANDUM OPINION AND ORDER

TUNHEIM, District Judge.

This matter is before the Court on plaintiff Cargill Inc.’s (“Cargill”) motion for summary judgment on its tax refund claim of approximately $3,175,506 plus interest for taxable years 1978, 1979, and 1980. The basis for Cargill’s claim is that it is the tax owner of an expansion to a grain terminal facility that it leases from the municipal government of the Port of Portland, Oregon. Cargill claims that it erroneously treated its interest in the expansion as a leasehold rather than an ownership interest, and as a result it deducted its…