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UNION CARBIDE CORP. v. UNITED STATES

No. 180-78.

612 F.2d 558 (1979)

UNION CARBIDE CORPORATION v. The UNITED STATES.

United State Court of Claims.

December 12, 1979.

Attorney(s) appearing for the Case

Raphael Sherfy, Washington, D. C., for plaintiff. Robert D. Heyde, Washington, D. C., atty. of record. William M. Bellamy, Jr., New York City, John F. Mooney, Stamford, Conn., Fred W. Peel, Jr., Little Rock, Ark., Miller & Chevalier, Washington, D. C., of counsel.

Marc M. Levey, Washington, D. C., with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D. C., for defendant. Theodore D. Peyser, Jr., Bruce W. Reynolds, Washington, D. C., of counsel.

Before DAVIS, KUNZIG and BENNETT, Judges.

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

BENNETT, Judge:

The plaintiff, Union Carbide Corporation, sues for a refund of federal income taxes and interest paid for the calendar year 1967.1 Plaintiff's recovery depends upon the proper method to be used in computing the reduction in the foreign tax credit required by I.R.C. § 1503(b)(1). The case is before the court on...

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