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TRUSTED MEDIA BRANDS, INC. v. U.S.

No. 17-3733-cv August Term 2017.

899 F.3d 175 (2018)

TRUSTED MEDIA BRANDS, INC., Fka The Readers Digest Association, Inc., Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Second Circuit.

Decided: August 10, 2018.

Attorney(s) appearing for the Case

DAVID B. BLAIR AND CLIFTON ELGARTEN , Crowell & Moring LLP, Washington, DC, for Trusted Media Brands, Inc.

TALIA KRAEMER AND BENJAMIN H. TORRANCE , Assistant U.S. Attorneys, for Geoffrey S. Berman , U.S. Attorney for the Southern District of New York, for United States of America

Before: Parker, Livingston, and Chin, Circuit Judges.

This appeal calls upon us to decide whether section 6511(d)(3)(A) of the Internal Revenue Code of 1986 (the "Code") — which establishes an elongated ten-year limitations period on refund claims resulting from foreign tax credits — is also applicable to claims resulting from...

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