Lockheed Martin Corp. v. United States

Opinion and Order

WEINSTEIN, Judge.

Plaintiff, Lockheed Martin Corporation (Lockheed), seeks a refund of $63,745,727 in federal income taxes for tax years 1984-1988. The case is before the court on the parties’ cross-motions for partial summary judgment on the so-called “subcontracts and materials issue.”1 The cross-motions concern plaintiffs claim that it is entitled to include, in calculating a tax credit, approximately $200 million in payments to various subcontractors as qualified research expense (QRE) for in-house research expenses for supplies (Supply QRE) pursuant to section…