Washington Mutual, Inc. v. United States
United States Court of Federal Claims
1Opinion of the Court
Tax Refund Claim; Cost Basis; Fair Market Valuation; Abandonment Loss Deduction; Amortization Deduction; Trial.
MEMORANDUM OPINION AND ORDER
GRIGGSBY, Judge
I. INTRODUCTION
Plaintiffs, Washington Mutual, Inc., Washington Mutual Bank, and Savings of America, Inc., seek a refund of certain federal taxes paid by H.F. Ahmanson & Co. (“Ahmanson”) as the parent company of an affiliated group of corporations including Home Savings of America (“Home”), during tax years 1991, 1994, 1996 and 1998, based upon the abandonment loss and amortization deductions under the Internal Revenue Code. During the 1980s,…
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