International Telephone & Telegraph Corp. v. Alexander

OPINION AND ORDER

SCHWARTZ, District Judge.

Plaintiff International Telephone & Telegraph Corporation (“ITT”) seeks judicial review of administrative action taken by defendant Donald C. Alexander in his capacity as Commissioner of Internal Revenue. The challenged action relates to defendant’s 1973 revocation of certain previously-issued private letter rulings, thereby giving rise to substantial unanticipated tax liabilities for a large number of ITT shareholders. Plaintiff contends the revocation was arbitrary, capricious, and beyond defendant’s statutory authority, and would have the Court…