Appeal Nos. 52-71, 453-71.

709 F.2d 1476 (1983)

GENERAL MOTORS CORPORATION, Plaintiff-Appellant, v. The UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

June 15, 1983.

Attorney(s) appearing for the Case

E. Alan Moorhouse, Detroit, Mich., for appellant. With him on brief were Otis M. Smith, Gen. Counsel, Paul H. Zalecki, Julius L. Russu and James A. Durkin. Ross L. Malone, Detroit, Mich., of counsel.

Allan C. Lewis, Washington, D.C., for appellee. With him on brief were Glenn L. Archer, Jr., Asst. Atty. Gen., Theodore D. Peyser and Robert S. Watkins, Washington, D.C.

Before MARKEY, Chief Judge, MILLER, Circuit Judge, and SKELTON, Senior Circuit Judge.

JACK R. MILLER, Circuit Judge.

Taxpayer ("GM") originated these actions under 26 U.S.C. § 6416(b)(1)1 in the United States Court of Claims to recover manufacturers excise taxes alleged to have been improperly assessed and collected for the period January 1, 1961, through December 31, 1966, in the amount of $2,466,162 in tax and $48,935.88 in assessed interest in No. 52-71 and $5,179,840 in tax and $124,200 in assessed interest in...

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