Pennzoil-quaker State Co. & Subsidiaries v. United States

*691OPINION

DAMICH, Chief Judge.

I. Introduction

Before the Court are Plaintiffs Motion for Partial Summary Judgment and the Cross-Motion of the United States for Summary Judgment (hereinafter “Def.’s X-Mot.”). In this action, Pennzoil-Quaker State Company and Subsidiaries (hereinafter “Plaintiff’) seeks a refund of $426,784 for the tax years 1994-97, due to taxes it paid to the United States Government (hereinafter “Defendant”) on income earned in the taxable years 1981-1995. Plaintiff asserts that it is entitled to relief under the Claim of Right Doctrine, which is set forth in 26 U.S.C. § 1341 (§…