Nalco Chemical Co. v. United States

MEMORANDUM OPINION AND ORDER

GETZENDANNER, District Judge:

This tax refund litigation concerns the deductibility of corporate payments to a nearly wholly-owned foreign subsidiary under the terms of an indemnification pledge. By agreement of the parties, trial has been held on stipulated facts and exhibits.1 The memorandum which follows constitutes the court’s findings of fact and conclusions of law.

I. Facts

Taxpayer Nalco Chemical Company (“Nalco”) is a Delaware corporation whose principal place of business is in Oak Brook, Illinois. Nalco manufactures and sells specialty chemicals and related…