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AMERICAN ELEC. POWER v. U.S.

Nos. C2-99-724, C2-98-304.

136 F.Supp.2d 762 (2001)

AMERICAN ELECTRIC POWER, INC., et. al., Plaintiffs, v. UNITED STATES of America, et al., Defendants. American Electric Power, Inc., et al., Plaintiffs, v. United States of America, et al., Defendants.

United States District Court, S.D. Ohio, Eastern Division.

February 20, 2001.

Attorney(s) appearing for the Case

Randolph C. Wiseman, Bricker & Eckler, Columbus, OH, Arthur L. Bailey, J. Walker Johnson, Jame P. Holden, Susan H. Serling, Jean Male Baxley, Steptoe& Johnson, Washington, DC, Richard E. May, Hunton & Williams, Washington, DC, of counsel, for Plaintiffs.

Dennis M. Donahue, Sp. Litigation Counsel, Office of Civ. Litigation, Tax Div., Washington, DC, James D. Hill, Office of Chief Counsel, Cincinnati, OH, Alex A. Sadler, Charles M. Ruchelman, Joseph A. Sergi, Tria; Atty's., Dept. of Justice, Tax Div., Washington, DC, Sharon J. Zealey, U.S. Atty., Deborah F. Sanders, U.S. Atty's. Office, Columbus, OH, for Defendants.

MEMORANDUM OPINION AND ORDER

GRAHAM, District Judge.

Introduction

This is a tax refund suit initiated by American Electric Power Company, Inc. ("AEP") to recover an alleged overpayment of federal income tax with respect to its 1996 tax year. AEP is a public utility holding company organized under the laws of the State of New York. Its principal office is in Columbus, Ohio. AEP is one of the largest shareholder-owned electric utility...

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