Beneficial Corp. v. United States

OPINION

MOODY R. TIDWELL, III, Judge:

This is a tax refund case which comes before this court under section 166(c) of the Internal Revenue Code of 1954 (hereinafter referred to as the Code) as codified in Title 26 of the United States Code. Plaintiff seeks a tax refund of federal income tax in the amounts of $21,137,455 and $8,559,114 for the taxable years 1976 and 1977, respectively. This case comes before us on defendant’s Motion for Summary Judgment and plaintiff’s Cross-Motion for Partial Summary Judgment. Jurisdiction is conferred upon the court pursuant to 28 U.S.C. § 1491. See Eastport…