Dresser Industries, Inc. v. United States

MELINDA HARMON, District Judge:

This is an appeal from a suit for tax refund in which the district court ruled against the taxpayer. Plaintiff-Appellant Dresser Industries, Inc. argues that the district court erred when it held on summary judgment that: (a) Treasury Regulation 1.861-8(e) disallows “interest netting”; (b) interest liability exists on deficiencies later eliminated or reduced by foreign tax credit carrybacks; and (c) such interest accrues until the filing date of the return of the tax year in which the foreign tax credit arises. Finding that the district court correctly ruled in…