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HONEYWELL, INC. v. U.S.

No. 91-3455.

973 F.2d 638 (1992)

HONEYWELL, INC., Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided August 21, 1992.

Attorney(s) appearing for the Case

James F. Carroll, Minneapolis, Minn., argued (James F. Carroll and Myron L. Frans, on the brief), for appellant.

Bridget M. Rowan, Washington, D.C., argued (James A. Bruton, Gary R. Allen, Ann B. Durney and Bridget M. Rowan, on the brief), for appellee.

Before WOLLMAN and HANSEN, Circuit Judges, and ROY, Senior District Judge.

ROY, Senior District Judge.

The plaintiff/appellant in this action, Honeywell, Inc. ("Honeywell"), sought to amend its 1979 income tax return in March of 1987 by claiming additional tax credits under the Work Incentive Training ("WIN") program. The Internal Revenue Service denied the claim, resulting in Honeywell bringing suit in the District Court for the District of Minnesota. Following the submission of cross-motions for summary judgment, the district court

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