Pohl Corp. v. United States

ORDER

MOODY R. TIDWELL, III, Judge:

This case is before the court on its own order requesting the parties to brief it on the issue of whether the court must issue an opinion when defendant, following trial, conceded that plaintiff was correct in its position and entitled to a tax refund for the full amount asserted in its complaint.

FACTS

On May 12, 1985, the Internal Revenue Service (IRS) issued a statutory notice of deficiency to plaintiff Pohl Corporation for the 1981 calendar year. On May 30, and December 30, 1986, plaintiff paid the IRS $9,443.00 and $204,500.00 respectively, representing…