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ALLIED CORP. v. UNITED STATES

Nos. 120-81T, 78-80T and 445-81T.

685 F.2d 396 (1982)

ALLIED CORPORATION v. The UNITED STATES. CASTLE & COOKE, INC. v. The UNITED STATES. REYNOLDS METALS COMPANY v. The UNITED STATES.

United States Court of Claims.

July 28, 1982.

Attorney(s) appearing for the Case

Karl R. Price, Washington, D. C., attorney of record, for plaintiff in No. 120-81T. W. F. Loftus and Ivins, Phillips & Barker, Washington, D. C., of counsel.

Paul H. Dawes, San Francisco, Cal., attorney of record, for plaintiff in No. 78-80T. George E. Link, Mary E. Butler, and Thelen, Marrin, Johnson & Bridges, San Francisco, Cal., of counsel.

Robert D. Heyde, Washington, D. C., for plaintiff in No. 445-81T; Raphael Sherfy, Washington, D. C., attorney of record. Hugh C. Stromswold, Charles J. Monahan, Thomas D. Johnston, and Miller & Chevalier, Chartered, Washington, D. C., of counsel.

Mildred L. Seidman, Washington, D. C., with whom was Asst. Atty. Gen. Glenn L. Archer, Jr., Washington, D. C., for defendant. Theodore D. Peyser and Bruce W. Reynolds, Washington, D. C., of counsel.

Before DAVIS, KASHIWA and SMITH, Judges.

ON THE PARTIES' CROSS MOTIONS FOR SUMMARY JUDGMENT AND PARTIAL SUMMARY JUDGMENT

KASHIWA, Judge:

These three cases are before the court on cross motions for summary judgment and partial summary judgment. All three concern the proper calculation method of the deduction granted Western Hemisphere trade corporations1 (hereinafter WHTCs) when consolidated federal income tax returns are filed. One also concerns the ability of a corporation...

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