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RAINBOW ELECTRIC COMPANY v. UNITED STATES

No. CV-81-77-GF.

536 F.Supp. 176 (1982)

RAINBOW ELECTRIC COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Montana, Great Falls Division.

March 3, 1982.

Attorney(s) appearing for the Case

Richard F. Gallagher, Church, Harris, Johnson & Williams, Great Falls, Mont., for plaintiff.

James P. Sites, Trial Atty., Tax Div., Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM AND ORDER

HATFIELD, District Judge.

Plaintiff commenced this civil tax refund action by filing a complaint against the United States on June 24, 1981. Defendant has filed a motion to dismiss on the grounds that the complaint fails to state a claim upon which relief can be granted. The motion to dismiss is well-taken, and is hereby granted.

FACTUAL BACKGROUND

Plaintiff's request for refund stems from corporate net operating losses...

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