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MICHIGAN RETAILERS ASS'N v. U.S.

No. G85-689-CA5.

676 F.Supp. 151 (1988)

MICHIGAN RETAILERS ASSOCIATION, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Michigan, S.D.

January 5, 1988.

Attorney(s) appearing for the Case

Stewart L. Mandill, Dykema, Gossett, Spencer, Goodnow & Trigg, Detroit, Mich., for plaintiff.

R. Todd Luoma, Tax Division, Dept. of Justice, Washington, D.C., for defendant.

OPINION OF THE COURT

BELL, District Judge.

This is an action under 26 U.S.C. § 7422 for refund of income taxes paid by plaintiff Michigan Retailers Association for tax years 1976 and 1977. Now before the Court are cross-motions for summary judgment under Fed.R.Civ.P. 56, supported by an extensive stipulation of facts.

I

Plaintiff Michigan Retailers Association, ("Association"), is a not...

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