RULING ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
DORSEY, District Judge.
Plaintiff, filer of consolidated tax returns for 1978 and 1979 for itself and affiliated corporations, 26 U.S.C. § 1504(a), Internal Revenue Code of 1954, Treasury Regulations § 1.1502-77, claims refunds of deficiencies assessed but paid, with accrued interest, $1,427,927 for 1978 and $814,650 for 1979. The claims, denied by the IRS, were based on:
(a) disallowed amortization...
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