Union Electric Company of Missouri v. The United States

DURFEE, Judge.

This is an action brought by the Union Electric Company of Missouri (hereinafter “Union Electric”) as successor of The North American Company (hereinafter “North American”) for refund of $1,181,178.97 plus interest thereon representing alleged overpayments of income tax and interest by the chain of corporations of which North American was the common parent, filing a consolidated tax return for 1952. The case comes before us on defendant’s motion for summary judgment, and the facts insofar as they are material to this motion are not in issue.

North American was incorporated in New…