Kraft, Inc. v. United States

OPINION

MOODY R. TIDWELL, III, Judge:

This is a suit for the refund of taxes in the amount of $94,702,599 paid by taxpayer following the disallowance of deductions by the Internal Revenue Service (IRS) for business losses arising out of the alleged abandonment of intangible assets in tax years 1972 through 1978. In the alternative taxpayer contends it is entitled to a capital loss if the court finds the disposition to have been a sale or exchange instead of an abandonment. Under Action (1)804-86T the complaint also contained counts for the refund of taxes for the alleged improper disallowance…