FEC Liquidating Corp. v. United States

Plaintiff sues to recover the Federal income taxes it paid upon gains realized from its sale of two blocks of Whittaker Corporation common stock, which plaintiff had acquired in exchange for its assets. Both parties move for summary judgment on plaintiff’s counts one and four, relating to its entitlement to the refund. Plaintiff’s other counts are not the subject of the motions before the court, nor the subject of this opinion. Since we grant defendant’s motions for summary judgment, however, we dismiss the portion of the petition that is affected.

The facts material to these motions are…