Albemarle Corporation & Subsidiaries v. United States

Tax; Foreign Tax Credit, 26 U.S.C. § 901; Motion to Dismiss; Statute of Limitations.

OPINION

HORN, J.

FINDINGS OF FACT

Plaintiff, Albemarle Corporation & Subsidiaries (Albemarle), filed a complaint in the United States Court of Federal Claims, seeking a tax refund in the amount of $825,846.00, plus interest, for taxes paid in the 1997 tax year and 1998 tax year. Plaintiff alleges that the Internal Revenue Service (IRS) incorrectly disallowed plaintiffs refund claims for foreign tax credits related to its Belgian subsidiary.

On December 31, 1996, a Belgian subsidiary of Albemarle, 1 Albemarle S.A.,…