Trinity Industries, Inc. v. United States
Court of Appeals for the Fifth Circuit
1Opinion of the Court
PRISCILLA R. OWEN, Circuit Judge:
Trinity Industries, Inc. (Trinity) designed and built vessels during the taxable years ending March 1994 and March 1995 (the claim years). On its amended tax returns, Trinity claimed research tax credits under Internal Revenue Code (I.R.C.) § 41 based on several of these vessel projects. The I.R.S. denied these claims. Trinity then filed this tax refund action in federal court, seeking research tax credits based on the projects. After a two-phase bench trial, the district court held that the tax credit due Trinity was $135,787.60 for 1994 and $0 for 1995.…
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