International Paper Co. v. United States

OPINION

REGINALD W. GIBSON, Judge.

INTRODUCTION

In this tax refund case, International Paper Company and its consolidated subsidiaries (plaintiff or IP) seek a refund of federal corporate income taxes in the total amount of $26.3 million, assessed by defendant for the years 1972 through 1979.1 Asserting that they are entitled to judgment as a matter of law pursuant to RCFC 56(b), the parties have each filed a motion for partial summary judgment with respect to three (3) distinct substantive issues.2 In support thereof, the parties assert that no material facts are in dispute and, accordingly,…