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MERCK & CO., INC. v. U.S.

No. 10-2775.

652 F.3d 475 (2011)

MERCK & CO., INC., Appellant, v. UNITED STATES of America.

United States Court of Appeals, Third Circuit.

Opinion Filed: June 20, 2011.

Attorney(s) appearing for the Case

Charles W. Hall,   William S. Lee,   Nancy T. Bowen,   Tom C. Godbold,   Reagan M. Brown, Fulbright & Jaworski, L.L.P., Houston, TX, Jonathan S. Franklin (argued), Tillman J. Breckenridge, Fulbright & Jaworski, L.L.P., Washington, D.C., Attorneys for Appellant.

John A. DiCicco,   Gilbert S. Rothenberg,   Kenneth L. Greene,   Judith A. Hagley (argued), Tax Division, Department of Justice, Washington, D.C., Attorneys for Appellee.

Before: FUENTES, SMITH, and GREENBERG, Circuit Judges.

OPINION OF THE COURT

FUENTES, Circuit Judge:

Plaintiff Schering-Plough, Inc.1 brings this action against the United States for recovery of nearly $500 million in taxes it claims the IRS incorrectly assessed against it. It argues, first, that the funds it received as a result of two transactions were not, as the IRS contends, immediately taxable in full as proceeds of loans from foreign subsidiaries; and, second, that it suffered...

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