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AM. STANDARD, INC. v. U.S.

No. 379-76.

602 F.2d 256 (1979)

AMERICAN STANDARD, INC., Successor to Westinghouse Air Brake Co. and Subsidiaries v. The UNITED STATES.

United States Court of Claims.

June 13, 1979.

Attorney(s) appearing for the Case

Robert B. Williams, Pittsburgh, Pa., attorney of record, for plaintiff. Carl Cherin, Steven W. McGrath, Dennis J. Lewis, Eckert, Seamans, Cherin & Mellott, Pittsburgh, Pa., of counsel.

Bruce W. Reynolds, Washington, D. C., with whom was Asst. Atty. Gen. M. Carr Ferguson, Washington, D. C., for defendant.

Before NICHOLS, KUNZIG and BENNETT, Judges.

OPINION

BENNETT, Judge.

The plaintiff, American Standard, Inc., seeks to recover overpayments of federal income taxes and interest for the taxable year ending December 31, 1966, and the taxable period ending May 31, 1968. The case concerns the proper method for computing the deduction for Western Hemisphere trade corporations (WHTC), I.R.C. §§ 921-922, when such corporations are members of an affiliated group which files a consolidated income tax...

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