Colorcon, Inc. v. United States

26 U.S.C. § 483; 26 U.S.C. § 163; Tax Refund; Unstated Interest; Interest Deduction; Deferred Payment; Short-Form Merger; In Lieu of Payment.

OPINION

FIRESTONE, Judge.

In this case, Colorcon, Inc. (“the plaintiff’ or “Colorcon”), formerly known as Berwind Pharmaceutical Services Incorporated (“BPSI”),1 seeks a refund for federal income taxes and the related penalty assessed and collected by the United States (“the government” or “the defendant”) for the tax year ending December 31, 2002, plus interest. The plaintiff had claimed an interest deduction in the amount of $31,096,7832 in connection…