BP Exploration & Oil Inc. v. United States

LOURIE, Circuit Judge.

BP Exploration & Oil Inc. appeals from the decision of the United States Court of Federal Claims granting the government’s motion for summary judgment that BP’s predecessor-in-interest, Sohio Petroleum Co. (“SPC”), was not entitled to deduct interest paid by its corporate parent, Standard Oil Company of Ohio, and other corporate affiliates (collectively “Standard Oil”) in determining SPC’s net income limitation for calculating its windfall profit tax. BP Exploration & Oil Inc. v. United States, 46 Fed. Cl. 526 (2000). Because we conclude that Standard Oil’s interest…