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AETNA CASUALTY AND SURETY CO. v. UNITED STATES

Civ. No. H-131.

403 F.Supp. 498 (1975)

The AETNA CASUALTY AND SURETY COMPANY, for itself and as successor by merger to the Aetna Casualty and Surety Company v. UNITED STATES of America.

United States District Court, D. Connecticut.

October 15, 1975.

Attorney(s) appearing for the Case

William G. Delana, J. Danford Anthony, Jr., Paul F. McAlenney, Hartford, Conn., for plaintiff.

Jerome Fink, and Robert M. Greco, Trial Attys., Tax Div., Dept. of Justice, Washington, D. C., Henry S. Cohn, Asst. U. S. Atty., Hartford, Conn., for defendant.

MEMORANDUM OF DECISION

BLUMENFELD, District Judge.

This is a tax refund suit involving the complex reorganization provisions of the Internal Revenue Code. The plaintiff seeks over $4.4 million dollars, plus interest, which it claims to have overpaid in taxes. A review of the background of this case will make this claim more understandable. The parties have stipulated to most (and disagree as to none) of the material facts and have entered cross-motions for...

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