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MAGMA POWER COMPANY v. U.S.

Case No. 09-419T.

MAGMA POWER COMPANY, AND MIDAMERICAN ENERGY HOLDINGS COMPANY AND SUBSIDIARIES Plaintiffs v. THE UNITED STATES OF AMERICA, Defendant.

United States Court of Federal Claims.

October 28, 2011.

Attorney(s) appearing for the Case

Gerald A. Kafka , with whom were Rita A. Cavanagh and Paul B. Hynes, Jr. , Washington, D.C., for Plaintiff.

Allison Ickovic , with whom were Robert J. Higgins , Steven I. Frahm , and John A. DiCicco , Department of Justice, Washington, D.C., for Defendant.

John M. Bergen , Law Clerk.

Samuel M. Poole , Legal Intern.

OPINION

LAWRENCE M. BASKIR, District Judge.

Plaintiff, Magma Power Company ("Magma Power") and its parent corporation, MidAmerican Energy Holdings Company and Subsidiaries ("MidAmerican"), seek a partial refund of the interest assessed against Magma Power, then an independent corporate entity, for tax year 1993 as a result of an underpayment of income taxes.

This case requires us to construe the phrase "same taxpayer" in relation...

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