Legal Opinion

Union Carbide Corp. v. United States

United States Court of Claims

Decided December 12, 1979No. 180-78PublishedCited by 18 opinions

1Opinion of the CourtBennett, Judge

The plaintiff, Union Carbide Corporation, sues for a refund of federal income taxes and interest paid for the calendar year 1967.1 Plaintiffs recovery depends upon the proper method to be used in computing the reduction in the foreign tax credit required by I.R.C. § 1503(b)(1). The case is before the court on plaintiffs motion for partial summary *79judgment2 and defendant’s cross-motion for summary judgment. We hold for plaintiff.

The basic facts of the case are not in dispute and may be simply stated. Plaintiff is the parent of an affiliated group of corporations which in the year in question…

2Cases cited11 opinions

  1. United States v. Felt & Tarrant Manufacturing Co.Supreme Court of the United States · 1931
  2. Real Estate - Land Title & Trust Co. v. United StatesSupreme Court of the United States · 1940
  3. American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
  4. Joseph Weidenhoff, Inc. v. CommissionerUnited States Tax Court · 1959
  5. American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956

6 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Clemon J. And Ivy C. Herrington v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  2. Ottawa Silica Company v. The United StatesCourt of Appeals for the Federal Circuit · 1983
  3. Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
  4. Union Carbide Corp. v. CommissionerUnited States Tax Court · 1980
  5. Union Carbide Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982

13 more not listed; retrieve them via the Exa API.

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