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IU INTERN. CORP. v. U.S.

No. 96-5084.

116 F.3d 1461 (1997)

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

United States Court of Appeals, Federal Circuit.

July 1, 1997.

Attorney(s) appearing for the Case

Irving Salem, Latham & Watkins, New York City, argued, for plaintiff-appellant. With him on the brief was Thomas G. Gallatin, Jr.

Mildred L. Seidman, Attorney, Tax Division, Department of Justice, Washington, DC, argued, for defendant-appellee. With her on the brief were Loretta C. Argrett, Assistant Attorney General, Gary R. Allen, Chief, Appellate Section, and Jonathan S. Cohen, Attorney.

Before PLAGER, CLEVENGER, and RADER, Circuit Judges.

RADER, Circuit Judge.

In this taxpayer refund suit, IU International Corporation (IU) claims the benefit of an increased stock basis in one of its affiliated subsidiary companies as a result of certain adjustments required during IU's corporate restructuring. The United States Court of Federal Claims properly found no authority in the Internal Revenue Code (I.R.C. or 26 U.S.C.) or Treasury regulations (26 C.F.R) that would allow IU to adjust its basis. See IU Int...

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