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DOMINION RESOURCES, INC. v. U.S.

Civ. A. No. 3:97CV326.

48 F.Supp.2d 527 (1999)

DOMINION RESOURCES, INC., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. Virginia, Richmond Division.

March 5, 1999.

Attorney(s) appearing for the Case

Virginia W. Powell, Hunton & Williams, Richmond, VA, Robert Joseph Muething, Hunton & Williams, Atlanta, GA, Winfield L. Ryan, Richmond, VA, for plaintiff.

James J. Wilkinson, U.S. Department of Justice, Tax Division, Washington, DC, Joan E. Evans, U.S. Attorney's Office, Richmond, VA, Alan J.J. Swirski, U.S. Department of Justice, Tax Division, Washington, DC, for defendant.

MEMORANDUM OPINION

PAYNE, District Judge.

Dominion Resources, Inc. ("DRI") instituted this action against the United States (the "IRS"), seeking a refund of federal taxes for the 1991 tax year, asserting four distinct tax claims. Having compromised Counts Three and Four of the original Complaint, DRI filed an Amended Complaint presenting only two counts.

In Count One of the Amended Complaint, DRI seeks a refund because the IRS erroneously refused...

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