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CSX CORP. v. U.S.

No. 96-2175.

124 F.3d 643 (1997)

CSX CORPORATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided September 11, 1997.

Attorney(s) appearing for the Case

Argued: Steven Wesley Parks, Tax Division, United States Department of Justice, Washington, DC, for Appellant. James Linwood Sanderlin, McGuire, Woods, Battle & Boothe, L.L.P., Richmond, VA, for Appellee. On Brief: Loretta C. Argrett, Assistant Attorney General, Richard Farber, Helen F. Fahey, United States Attorney, Tax Division, United States Department of Justice, Washington, DC, for Appellant. Courtney G. Hyers, CSX Corporation, Richmond, VA; James D. Bridgeman, McGuire, Woods, Battle & Boothe, L.L.P., Washington, DC, for Appellee.

Before NIEMEYER, MICHAEL, and MOTZ, Circuit Judges.

Reversed by published opinion. Judge MOTZ wrote the opinion, in which Judge NIEMEYER and Judge MICHAEL joined.

OPINION

DIANA GRIBBON MOTZ, Circuit Judge:

This case involves the now repealed "book income" provisions of the alternative minimum tax applicable to corporate taxpayers. Proper calculation of a corporation's "book income" is a somewhat esoteric endeavor, but was critically important to corporations that had high "book incomes" and low taxable...

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