Legal Opinion

Washington Mutual, Inc. v. United States

United States Court of Federal Claims

Decided February 21, 2017No. 08-321T, 08-211TPublishedCited by 7 opinions

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,…

2Cases cited39 opinions

  1. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  2. United States v. TestanSupreme Court of the United States · 1976
  3. United States v. MitchellSupreme Court of the United States · 1983
  4. Blonder-Tongue Laboratories, Inc. v. University of Illinois FoundationSupreme Court of the United States · 1971
  5. United States v. JanisSupreme Court of the United States · 1976

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3Cited by7 opinions

  1. Wmi Holdings Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2018
  2. Confidential Informant 59-05071 v. United StatesUnited States Court of Federal Claims · 2017
  3. U.S. Bank National Assoc. v. S.D. Dept of RevenueSouth Dakota Supreme Court · 2022
  4. ALTA WIND I OWNER LESSOR C v. United StatesUnited States Court of Federal Claims · 2026
  5. Alternative Carbon Resources, LLC v. United StatesUnited States Court of Federal Claims · 2018

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