ESCO Corp. v. United States

OPINION

REDDEN, Judge:

In this action, plaintiff ESCO Corporation (ESCO)1 seeks a refund of federal income taxes for the years 1973, 1974 and 1975. Its claims were tried to the court on stipulated facts on July 8, 1983. In addition, experts for both sides testified. This opinion constitutes my findings of fact and conclusions of law in accordance with Fed. R.Civ.P. 52(a).

I. Background

The parties’ stipulation of facts is incorporated by reference herein. I, therefore, give only a brief recitation of the facts. ESCO is an Oregon corporation which operates a metal fabrication plant in Portland,…