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EXXON CORP. v. UNITED STATES

Appeal No. 85-2160.

785 F.2d 277 (1986)

EXXON CORPORATION, Appellant, v. The UNITED STATES, Appellee.

United States Court of Appeals, Federal Circuit.

January 15, 1986.

Attorney(s) appearing for the Case

Robert L. Moore, II, of Miller & Chevalier, Washington, D.C., argued for appellant. Of counsel were Jennings T. Smith, Exxon Corp., New York City, John B. Magee, Thomas D. Johnston and J. Bradford Anwyll, of Miller & Chevalier, Washington, D.C.

Theodore D. Peyser, Dept. of Justice, Tax Div., Washington, D.C., argued for appellee. With him on brief were Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Jonathan S. Cohen.

Before MARKEY, Chief Judge, DAVIS, and BISSELL, Circuit Judges.

BISSELL, Circuit Judge.

Exxon Corporation (Exxon) appeals from a partial judgment dismissing its tax refund claim based upon a disallowance by the Commissioner of Internal Revenue Service of a bad debt deduction. We reverse the decision of the United States Claims Court reported at 7 Cl.Ct. 347 (1985).

BACKGROUND

This litigation involves a claim to a bad debt deduction based entirely on transactions within...

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