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TRANSAMERICA CORP. v. U.S.

No. 89-1428.

902 F.2d 1540 (1990)

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

United States Court of Appeals, Federal Circuit.

May 8, 1990.

Attorney(s) appearing for the Case

Cameron W. Wolfe, Jr. of Orrick, Herrington & Sutcliffe, San Francisco, Cal., argued for plaintiff-appellant. Of counsel were Robert J. Favole and Ruth L. Robinson.

Jonathan S. Cohen, of the Dept. of Justice, Washington, D.C., argued for defendant-appellee. With him on the brief were Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and Calvin C. Curtis.

David Cohen of Cohen & Fthenakis, Palo Alto, Cal., was on the brief for amicus curiae The Nat. Center for Film and Video Preservation.

NIES, Circuit Judge, SKELTON, Senior Circuit Judge, BISSELL, Circuit Judge.

NIES, Circuit Judge.

Transamerica Corporation (taxpayer) appeals from the judgment of the United States Claims Court, 15 Cl.Ct. 420 (1988), (Harkins, Sr. J.) affirming the disallowance of taxpayer's claim for a charitable contribution deduction under 26 U.S.C. § 170(a)(1) (1982) in the amount of $10,045,480 for the taxable year ending December, 1969, by reason of the transfer of certain rights in motion picture film stock to the Library of Congress. We affirm...

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