Legal Opinion
Federal Express Corp. v. United States
District Court, W.D. Tennessee
Decided October 7, 1986No. 83-2474 GAPublishedCited by 3 opinions
1Opinion of the Court
MEMORANDUM OPINION
GIBBONS, District Judge.
Plaintiff Federal Express Corporation, a Delaware corporation with its principal place of business in Memphis, Tennessee, has brought this action under 28 U.S.C. § 1346(a)(1) to recover an alleged overpayment of taxes for the years 1978 and 1979.
Pursuant to a Purchase Agreement dated November 9, 1973, Federal Express sold 122,500 shares of Convertible Preferred Stock, $100 par value, and $12,250,000.00 principal amount of Subordinated Promissory Notes due October 1, 1981. In September 1974 plaintiff sold $3,876,000.00 principal amount of 8%…
2Cases cited14 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Paul W. Berthold and Dorothy Berthold v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
- Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
- Laurie W. Tomlinson, District Director of Internal Revenue for the District of Florida v. The 1661 CorporationCourt of Appeals for the Fifth Circuit · 1967
- George T. Smith and Clela v. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1966
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3Cited by3 opinions
- American Financial Group v. United StatesDistrict Court, S.D. Ohio · 2010
- Indmar Prods. Co. v. Comm'rUnited States Tax Court · 2005
- Lease v. CommissionerUnited States Tax Court · 1993