Silco, Inc. v. United States

MEMORANDUM OPINION AND ORDER

ROBERT M. HILL, District Judge.

Came on for consideration before the Court a civil action for a refund of federal income taxes paid by plaintiff, Silco, Inc. (Silco). The case has been submitted for determination on stipulated facts. Jurisdiction is proper under 28 U.S.C. § 1346(a)(1). Having considered the parties’ briefs and the relevant case law, as well as having heard oral argument of counsel, the Court is of the opinion that the claim for refund should be denied. Accordingly, judgment shall be entered in favor of the United States.

I. Facts and Issue

This is an…