Woodmont Terrace, Inc. v. United States

MEMORANDUM

FRANK GRAY, Jr., District Judge.

This civil action was instituted by Woodmont Terrace, Inc. (hereinafter called plaintiff) against the United States of America (hereinafter called defendant) for recovery of an alleged overpayment of federal corporate income taxes. It is now before the court on the motions of both parties for summary judgment.

Plaintiff was at all times relevant to this controversy a Tennessee corporation with its principal place of business in Nashville, Tennessee, and was engaged in the activity of holding property for rental purposes. Plaintiff employed the accrual…