Legal Opinion
AMP Inc. & Consolidated Subsidiaries v. United States
United States Court of Federal Claims
Decided January 15, 1998No. 94-248TPublishedCited by 2 opinions
1Opinion of the Court
Order1
WEINSTEIN, Judge.
The parties have cross-moved for summary judgment. Plaintiffs motion is denied, and defendant’s cross-motion is granted.
Plaintiff AMP Inc. brought this action to recover claimed overpayments of federal corporate income taxes for 1981 and 1982. The overpayments allegedly are for insufficient claimed foreign tax credits, under Internal Revenue Code2 sections 901 and 902, with respect to the foreign tax paid by its wholly-owned Brazilian subsidiary, AMP do Brasil Conectores Eléctricos E Eletronicos Limitada (“AMP Brasil”).
The amounts of the foreign tax credits originally…
2Cases cited14 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Biddle v. CommissionerSupreme Court of the United States · 1938
- Frank F. And Judith J. Foil v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- United States v. Allen F. Campbell and A.F. Campbell & Co., Inc.Court of Appeals for the Fifth Circuit · 1990
9 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Amp Incorporated and Consolidated Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 1999
- Burson v. United StatesUnited States Court of Federal Claims · 2026