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UNITED DOMINION INDUSTRIES, INC. v. U.S.

No. 98-2380.

208 F.3d 452 (2000)

UNITED DOMINION INDUSTRIES, INCORPORATED, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided: March 24, 2000.

Attorney(s) appearing for the Case

Argued: Richard Farber, United States Department of Justice, Washington, D.C. for Appellant. Eric R. Fox, Ivins, Phillips & Barker, Washington, D.C. for Appellee. On Brief: Edward T. Perelmuter, U.S. Department of Justice, Washington, D.C. for Appellant. Dirk J.J. Suringa, Ivins, Phillips & Barker, Washington, D.C. for Appellee.

Before TRAXLER and KING, Circuit Judges, and SEYMOUR, United States District Judge for the District of South Carolina, sitting by designation.

Reversed and remanded by published opinion. Judge KING wrote the opinion, in which Judge TRAXLER and Judge SEYMOUR joined.

OPINION

KING, Circuit Judge:

The question in this case arises from the filing of consolidated tax returns by the predecessor of plaintiff United Dominion Industries, Incorporated (the "taxpayer" or "AMCA"1). The taxpayer and the Government (the "IRS") disagree...

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