Volvo Trucks of North America, Incorporated, Formerly Known as Volvo Gm Heavy Truck Corporation v. United States

Affirmed by published opinion. Judge Niemeyer wrote the opinion, in which Judge Wilkinson and Judge Duncan joined.

NIEMEYER, Circuit Judge:

Volvo Trucks of North America, Inc. commenced this action against the Internal Revenue Service (“IRS”) to obtain an $856,226 refund of federal excise taxes paid under 26 U.S.C. § 4051(a) for heavy trucks that Volvo sold to its dealers during the 1989-91 period. Volvo claimed to be entitled to an exemption from the tax, but the IRS disallowed the exemption because Volvo failed to support its claim with the documentation required by Temporary Treasury…