Yamaha Motor Corp., U.S.A. v. United States

MEMORANDUM OPINION

CHARLES R. RICHEY, District Judge.

Plaintiffs Yamaha Motor Corporation, U.S.A., and Yamaha Parts Distributors, Inc., (hereinafter “Yamaha”) allege that the Defendants United States of America, the Internal Revenue Service, and various individuals in their official capacities acted arbitrarily, capriciously and in an abuse of discretion by refusing to enter into negotiations with the Japanese government upon the Plaintiffs’ invocation of the Double Tax Treaty. 1 Invoking the Court’s power to enforce the Treaty, the Administrative Procedure Act, 5 U.S.C. § 701 et seq., and 28…