Robbins Tire and Rubber Company, Inc. v. United States

CLARK, Circuit Judge:

The contract interpretation issue in this appeal arose in the context of a tax claim settlement. Finding that only one reasonable meaning may be ascribed to the compromise offer and acceptance agreement of the parties, we reverse the action of the trial court in treating the contract as ambiguous and in submitting the issue of its interpretation to jury resolution.

Robbins Tire & Rubber Company (Taxpayer), an Alabama corporation, chose to file its tax returns on a September 30th fiscal year basis. During its 1942-1963 operations, Taxpayer incurred unpaid liability claims…