Amax Coal Co. v. United States

MEMORANDUM OPINION

BROOKS, District Judge.

The Court, having heard all the evidence and arguments of the parties, now enters its findings of fact and conclusions of law consistent with Federal Rule of Civil Procedure 52(a). Any conclusion of law mischaracter-ized as fact shall be hereby deemed a statement of fact and conversely any statement of fact improperly labeled a conclusion of law shall be deemed a statement of fact.

Findings of Fact

This case concerns the assessment of Black Lung Excise Taxes (“BLET”). Federal legislation of coal mining commenced shortly after, and arguably in response…