Browning-Ferris Industries, Inc. & Subsidiaries v. United States

This is a tax case. The United States appeals from the final decision of the United States Court of Federal Claims holding that, pursuant to a particular Treasury Regulation, Browning-Ferris Industries, Inc. (“Inc.”) is deemed to have liquidated on December 31, 2004, and thus liquidated no longer qualified to act as the proper agent for a consolidated group of subsidiary companies for which it, before the deemed liquidation, had been the common parent. Browning Ferris Indus., Inc. v. United States, 75 Fed.Cl. 591 (2007). We reverse and remand.

I

The parties know the facts of this case, which…