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BAKER HUGHES, INC. v. U.S.

No. 18-20585.

943 F.3d 255 (2019)

BAKER HUGHES, INCORPORATED, Plaintiff-Appellant v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

FILED November 21, 2019.

Attorney(s) appearing for the Case

Reagan Mark Brown , Stephen Allen Kuntz , Robert Clay Morris , Norton Rose Fulbright US, L.L.P., Houston, TX, for Plaintiff-Appellant.

Jacob Earl Christensen , Cory Arthur Johnson , Gilbert Steven Rothenberg, Esq. , Senior Attorney, Rika Valdman , U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, for Defendant-Appellee.

Before SOUTHWICK, WILLETT, and OLDHAM, Circuit Judges.

In this dispute over an income tax deduction, the taxpayer appeals the decision of the district court that a $52 million payment from its predecessor in interest to the predecessor's subsidiary was not a bad debt under 26 U.S.C. § 166 or an ordinary and necessary business expense under 26 U.S.C. § 162...

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