Legal Opinion

Shell Petroleum, Inc. v. United States

District Court, D. Delaware

Decided October 16, 1997No. CIV. A. 93-508-JJFPublishedCited by 7 opinions

1Opinion of the Court

MEMORANDUM OPINION

FARNAN, Chief Judge.

I. BACKGROUND

This is an action brought by Plaintiff, Shell Petroleum Inc. (“Shell”), pursuant to 26 U.S.C. § 7422 for the refund of claimed overpaid federal income taxes and interest due thereon under 26 U.S.C. § 6611. Shell is incorporated under the laws of the State of Delaware and maintains a principal office in Delaware at 1105 Market Street, Wilmington, Delaware, 19899. (D.I. 296 at Í2(a)). Shell is the common parent of an affiliated group of corporations (the “Shell Affiliated Group”). The Shell Affiliated Group files consolidated federal income tax…

2Cases cited17 opinions

  1. United States v. American Trucking AssociationsSupreme Court of the United States · 1940
  2. United States v. JanisSupreme Court of the United States · 1976
  3. Perrin v. United StatesSupreme Court of the United States · 1979
  4. McDermott International, Inc. v. WilanderSupreme Court of the United States · 1991
  5. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934

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3Cited by7 opinions

  1. Shell Petroleum, Inc., and Subsidiary Corporations v. United StatesCourt of Appeals for the Third Circuit · 1999
  2. Shell Petroleum, Inc., and Subsidiary Corporations v. United StatesCourt of Appeals for the Federal Circuit · 2003
  3. San Juan Basin Consortium, Ltd. v. Enervest San Juan Acquisition Ltd. PartnershipDistrict Court, D. Colorado · 1999
  4. Shell Petroleum, Inc. v. United StatesUnited States Court of Federal Claims · 2001
  5. Shell Petroleum v. United StatesCourt of Appeals for the Third Circuit · 1999

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