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ARKLA, INC. v. U.S.

No. 94-5023.

37 F.3d 621 (1994)

ARKLA, INC., Plaintiff-Appellant, v. The UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

October 4, 1994.

Attorney(s) appearing for the Case

Lawrence L. Jones, Atty., Blanchard, Walker, O'Quin & Roberts, Shreveport, LA, argued, for appellant. Of counsel were J. Edgerton Pierson, Jr. and Frederick R. Parker, Jr.

Thomas J. Clark, Atty., U.S. Dept. of Justice, Washington, DC, argued, for appellee. With him on the brief were Loretta C. Argrett, Acting Asst. Atty. Gen., Gary R. Allen and Jonathan S. Cohen.

Before MAYER, MICHEL and LOURIE, Circuit Judges.

MICHEL, Circuit Judge.

Arkla, Inc. appeals the Court of Federal Claims' grant of summary judgment for the government, denying Arkla's claim for income tax refunds in two related cases, Arkla, Inc. v. United States, 27 Fed.Cl. 226 (1992) (Arkla II), and Docket No. 90-3954T, decided September 13, 1993. Arkla claimed refunds for taxes and assessed interest paid for the years 1981 through 1984 based on the Internal Revenue Service's (IRS) denial of an investment...

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