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ARISTAR, INC. v. UNITED STATES

No. 292-75.

553 F.2d 644 (1977)

ARISTAR, INC. v. The UNITED STATES.

United States Court of Claims.

April 20, 1977.

Attorney(s) appearing for the Case

Richard J. Hiegel, New York City, atty. of record, for plaintiff. Alvin J. Goldman, New York City, of counsel.

Allan C. Lewis, Washington, D.C., with whom was Acting Asst. Atty. Gen. Myron C. Baum, Washington, D.C., for defendant. Theodore D. Peyser and Robert S. Watkins, Washington, D.C., of counsel.

Before COWEN, Senior Judge, and DAVIS and SKELTON, Judges.

ON PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT

SKELTON, Judge:

Plaintiff (taxpayer) in this case is a holding company with approximately 450 subsidiaries engaged in the consumer finance business in some 30 states. Plaintiff, itself, is not actively engaged in business and during the fiscal years in question (1964, 1965, and 1966) had only a minor amount of assets besides...

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