Thompson Truck & Trailer, Inc. v. United States

WOLLMAN, Circuit Judge.

Thompson Truck & Trailer, Inc. (Thompson), appeals the dismissal of its complaint, arguing that the district court 1 erred in interpreting 26 U.S.C. § 4051 (a)(1). We affirm.

Thompson is a semitruck dealership, whose principal offices are located in Cedar Rapids, Iowa. Thompson sells trucks equipped with diesel particulate filters (filters). The filters collect particulate matter from a truck's exhaust and turn it into a less harmful substance. Each filter increases a truck's retail sales price by approximately $8,000. Under Internal Revenue Code § 4051(a)(1), Thompson…