Wrangler Apparel Corp. v. United States

MEMORANDUM OPINION

BEATY, District Judge.

This matter is before the Court on Plaintiff and Defendant’s Motions for Summary Judgment.

I. FACTUAL BACKGROUND

This is an action for a tax refund of $17,-730,600 based upon an alleged “greenmail” payment made in connection with the purchase of common stock. Plaintiff, Wrangler Apparel Corp., merged with Blue Bell, Inc. (“Blue Bell”) and has assumed Blue Bell’s tax refund claim, though the events which give rise to this refund claim occurred while Blue Bell was an independent entity.

From 1981 to November 1983 various entities controlled by the Bass…