REYNOLDS METALS CO. v. U.S.

No. Civ.A. 3:02CV670-JRS.

389 F.Supp.2d 692 (2005)

REYNOLDS METALS COMPANY, et al., Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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

August 22, 2005.


Attorney(s) appearing for the Case

Thomas Arthur Clare, Kirkland & Ellis, Washington, DC, Natalie Hoyer Keller, Kirkland & Ellis, Chicago, IL, for Plaintiffs.

Michael J. Martineau, Trial Attorney, Tax Division, U.S. Dept. of Justice, Washington, DC, Robert P. McIntosh, United States Attorney's Office, Richmond, VA, for Defendant.


MEMORANDUM OPINION

SPENCER, District Judge.

THIS MATTER is before the Court on the parties' cross motions for partial summary judgment.1 Reynolds Metals Co. ("Reynolds") is seeking a total tax refund of $22,271,747.00 which it claims resulted from the overstatement of its gross income from 1940 through 1987.

"Summary judgment is appropriate only if the pleadings, depositions, answers to interrogatories and admissions...

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