Sprint Nextel Corp. and Subsidiaries v. United States

MEMORANDUM AND ORDER

KATHRYN H. VRATIL, District Judge.

Plaintiffs bring suit against the United States seeking a refund of federal income taxes paid for the taxable years that ended December 31,1990 through 1994, and certain tax credits from the taxable year that ended December 31, 1988. Plaintiffs argue that they are entitled to the refund and tax credits because they incorrectly treated payments from the Federal Communications Commission (“FCC”) Universal Service Fund (“USF”) as taxable gross income instead of nontaxable nonshareholder contributions to capital. 1 The government disagrees. It…