Legal Opinion
RJR Nabisco, Inc. v. United States
District Court, N.D. Georgia
Decided January 16, 1991No. 1:89-cv-2109-GETPublishedCited by 1 opinion
1Opinion of the Court
ORDER
G. ERNEST TIDWELL, District Judge.
The above-styled motion is before the court on cross-motions for summary judgment.
In this proceeding, plaintiff, RJR Nabisco, Inc. (“RJR”), seeks to recover a portion of the interest payment it paid to the defendant, the Internal Revenue Service (“IRS”), on a tax deficiency and penalty. All of the facts have been stipulated to and both parties have filed motions for summary judgment.
On August 22, 1980 the IRS assessed an income tax deficiency against RJR for the taxable years 1971-1974. On February 1, 1982, RJR paid $60 million to the IRS pursuant to an…
2Cases cited5 opinions
- Greyhound Corp. v. Mt. Hood Stages, Inc.Supreme Court of the United States · 1978
- Cabalceta v. Standard Fruit Co.Court of Appeals for the Eleventh Circuit · 1989
- Herbert M. Gannet and Ruth Gannet v. The United StatesCourt of Appeals for the Federal Circuit · 1989
- Phillip Purer Winifred Purer v. United StatesCourt of Appeals for the Ninth Circuit · 1989
- J. Bradley Cohn and Elizabeth R. Cohn, on Behalf of Themselves and All Others Similarly Situated v. United StatesCourt of Appeals for the Second Circuit · 1989
3Cited by1 opinion
- Rjr Nabisco, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1992