United States Federal Circuit

In a dispute involving whether a parent and its subsidiaries, which incurred overpayments and underpayments prior to consolidation, qualify as the same tax-payer under I.R.C.section 6621(d), judgment of the trial court denying plaintiff-parent company a tax refund is affirmed where under section 6621(d), plaintiff is not the same tax-payer as its subsidiary.

Appellate Information

• Decided 06/20/2011
• Published 06/20/2011

Judges

• GAJARSA

Court

• United States Federal Circuit

Counsel