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PETROLEUM CORP. OF TEXAS, INC. v. U.S.

No. 90-1620.

939 F.2d 1165 (1991)

PETROLEUM CORPORATION OF TEXAS, INC. and Subsidiaries, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

August 26, 1991.

Attorney(s) appearing for the Case

Emily A. Parker, Dennis J. Grindinger, Thompson & Knight, Dallas, Tex., for plaintiffs-appellants.

Teresa T. Milton, Gary R. Allen, Chief, Kenneth L. Greene, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., Marvin Collins, U.S. Atty., Dallas, Tex., for defendant-appellee.

Before BROWN, SMITH and WIENER, Circuit Judges.

WIENER, Circuit Judge:

Plaintiffs-Appellants, Petroleum Corporation of Texas (Petco) and its subsidiaries (collectively, Taxpayers), sued for refund of income taxes paid for the tax periods ending April 20, 1981, and November 30, 1983, in the total amount of $3,749,291, and for statutory interest. The district court denied Taxpayers' request for refund, holding that the corporations' liquidating distributions to shareholders of the corporations' interests in three...

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