Celanese Corp. v. United States

OPINION ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT AND PLAINTIFF’S CROSS-MOTION FOR PARTIAL SUMMARY JUDGMENT

PHILIP R. MILLER, Judge:

This is a suit for refund of $19,075,994 in income tax, plus interest. The question at issue on these motions is the right of plaintiff, Celanese Corporation, to deduct $58,-364,636 as a bad debt loss, ordinary loss or business expense on its 1969 federal income tax return, as a result of having paid that sum in satisfaction of its guarantees of the debts of an Italian subsidiary corporation during that year.

Statement

Since defendant’s motion for summary judgment…