HEANEY, Senior Circuit Judge.
Varied Investments, Inc., ("Varied") appeals the denial of its claim for a tax refund of $4,980,949.62 it paid as a deficiency assessment arising from the Internal Revenue Service's disallowance of a deduction it took under 26 U.S.C. § 461(f). Varied argued that it satisfied the requirements of section 416(f) and therefore was entitled to the deduction. We agree and reverse the judgment of the district court.
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