OPINION
MARIAN BLANK HORN, District Judge.
FINDINGS OF FACT
Plaintiff, Albemarle Corporation & Subsidiaries (Albemarle), filed a complaint in the United States Court of Federal Claims, seeking a tax refund in the amount of $825,846.00, plus interest, for taxes paid in the 1997 tax year and 1998 tax year. Plaintiff alleges that the Internal Revenue Service (IRS) incorrectly disallowed plaintiff's refund claims for foreign tax credits related...
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