Petroleum Corporation of Texas, Inc. And Subsidiaries v. United States

WIENER, Circuit Judge:

Plaintiffs-Appellants, Petroleum Corporation of Texas (Petco) and its subsidiaries (collectively, Taxpayers), sued for refund of income taxes paid for the tax periods ending April 20, 1981, and November 30, 1983, in the total amount of $3,749,291, and for statutory interest. The district court denied Taxpayers’ request for refund, holding that the corporations’ liquidating distributions to shareholders of the corporations’ interests in three partnerships should be treated for tax purposes as distributions of the specific property owned by the three partnerships and thus…