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AMERICAN HOME PRODUCTS CORP. v. UNITED STATES

No. 422-75.

601 F.2d 540 (1979)

American Home Products Corporation v. The UNITED STATES.

United States Court of Claims.

June 13, 1979.

Attorney(s) appearing for the Case

William M. Chanson, New York City, Atty. of Record, for plaintiff.

Bruce W. Reynolds, Washington, D.C., with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D.C., for defendant; Theodore D. Peyser and Robert S. Watkins, Washington, D.C., of counsel.

Before DAVIS, KASHIWA and KUNZIG, Judges.

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

DAVIS, Judge:

This case involves the tax effects of certain forward sale contracts of foreign currency. We must first determine the proper amount of dividends declared in British pounds when the American taxpayer immediately applied most of the dividends it received to cover two of its forward sale contracts of pounds into dollars. We conclude that the dividends...

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