Legal Opinion
Harco Holdings, Inc. v. United States
District Court, N.D. Illinois
Decided December 21, 1990No. 89 C 3988PublishedCited by 5 opinions
1Opinion of the Court
ORDER
NORGLE, District Judge.
Before the court is plaintiff Harco Holdings, Inc.’s (“Harco”) motion for summary judgment. For the reasons discussed below, the motion is denied.
FACTS 1
On September 15, 1979, Harco filed a timely federal corporate income tax return for the taxable year ending on December 31, 1978. This filing consolidated the tax returns of Harco and three of its wholly-owned subsidiaries. Along with this filing, Harco submitted full payment of the $2,559,397 in taxes computed on the return.
On February 3, 1982, Harco timely filed with the IRS a refund claim for $790,794. In this…
2Cases cited2 opinions
- United States v. Occidental Life Insurance Company of California, a California CorporationCourt of Appeals for the Ninth Circuit · 1967
- Time Ins. Co. v. CommissionerUnited States Tax Court · 1986
3Cited by5 opinions
- Harco Holdings, Incorporated, and Subsidiaries v. United StatesCourt of Appeals for the Seventh Circuit · 1992
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- BEST LIFE ASSUR. CO. v. COMMISSIONERUnited States Tax Court · 2000
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- Central Reserve Life Corporation and Subsidiaries v. CommissionerUnited States Tax Court · 1999