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CONSOLIDATED EDISON CO. OF NEW YORK, INC. v. U.S.

Docket No. 85-6114.

782 F.2d 322 (1986)

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided January 14, 1986.

Attorney(s) appearing for the Case

Ernest J. Williams, New York City, for plaintiff-appellant.

Gerald T. Ford, and Steven E. Obus, Asst. U.S. Attys., for defendant-appellee.

Before PIERCE, WINTER and DAVIS, Circuit Judges.

PER CURIAM:

The Consolidated Edison Company of New York (Con Ed) appeals from a judgment of the United States District Court for the Southern District of New York, Motley, Chief Judge, dismissing its complaints in two consolidated actions in which Con Ed sought a tax refund of $412,420 paid during the taxable years from July 1, 1972 through June 30, 1977 and July 1, 1979 through June 30, 1982. The district court ruled that sections 4481 and 4482 of the Internal...

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