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GENERAL ELEC. CO. v. UNITED STATES

No. 429-76.

610 F.2d 730 (1979)

GENERAL ELECTRIC COMPANY, v. The UNITED STATES.

United States Court of Claims.

November 14, 1979.

Attorney(s) appearing for the Case

M. Bernard Aidinoff, New York City, attorney of record, for plaintiff; Charles E. Dorkey, III, Sydney E. Unger, and Sullivan & Cromwell, New York City, of counsel.

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

Before KASHIWA, KUNZIG and BENNETT, Judges.

OPINION

KASHIWA, Judge:

This income tax case comes before the court on the parties' stipulation of facts. General Electric Co. (GE) seeks a refund for taxes and interest paid for its 1966 tax year. The issues presented in this case1 involve interpretation of the regulations promulgated under I.R.C. § 963. We must decide whether plaintiff was correct in applying the special rules of Treas.Reg. § 1.963-4 in determining...

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