Legal Opinion

Doyon, Ltd. v. United States

United States Court of Federal Claims

Decided November 22, 1996No. 94-1074TPublishedCited by 11 opinions

1Opinion of the Court

OPINION

REGINALD W. GIBSON, Senior Judge:

INTRODUCTION

In this tax refund case, Doyon, Limited (Doyon or plaintiff) seeks a refund of federal corporate income taxes in the total amount of $746,9421 assessed by defendant for the year 1988. Doyon is an Alaska Native Corporation (ANC). During the years 1987 and 1988, Doyon entered into several agreements with various corporations to sell its net operating losses (NOLs) and investment tax credits (ITCs), pursuant to § 60(b)(5) of the Deficit Reduction Act of 1984 (DEFRA). The Commissioner of Internal Revenue (Commissioner) reviewed these…

2Cases cited30 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Welch v. HelveringSupreme Court of the United States · 1933
  4. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  5. United States v. ButlerSupreme Court of the United States · 1936

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3Cited by11 opinions

  1. Doyon, Limited v. United StatesCourt of Appeals for the Federal Circuit · 2000
  2. Gargoyles, Inc. v. United StatesUnited States Court of Federal Claims · 1999
  3. Stelco Holding Co. v. United StatesUnited States Court of Federal Claims · 1999
  4. Salem Financial, Inc. Ex Rel. Branch Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2015
  5. Santander Holdings USA, Inc. & Subsidiaries v. United StatesDistrict Court, D. Massachusetts · 2013

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