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MOTORS INS. CORP. v. UNITED STATES

Nos. 132-73 and 133-73.

530 F.2d 864 (1976)

MOTORS INSURANCE CORPORATION v. The UNITED STATES. MOTORS INSURANCE CORPORATION, Successor in Interest to General Exchange Insurance Corporation v. The UNITED STATES

United States Court of Claims.

January 28, 1976.

Attorney(s) appearing for the Case

E. Alan Moorhouse, Washington, D.C., attorney of record, for plaintiff; Frazer F. Hilder and Paul H. Zalecki, Detroit, Mich., of counsel.

Bruce W. Reynolds, Washington, D.C., with whom was Asst. Atty. Gen. Scott P. Crampton, Washington, D.C., for defendant; Theodore D. Peyser, Jr., and John E. Evans, Washington, D.C., of counsel.

Before DURFEE, Senior Judge, SKELTON and BENNETT, Judges.

OPINION

BENNETT, Judge.

This income tax refund litigation comes before us upon a stipulation of facts pursuant to Rule 134(b) of the Rules of this court. Because of similarity of issues, the cases are consolidated for decision. We are invited in each case to decide issues involving the foreign tax credit, which the parties represent to be questions of first impression. First, where a corporate taxpayer seeks a net operating loss carryback adjustment for...

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