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NALCO CHEM. CO. & SUBSIDIARIES v. UNITED STATES

No. 79 C 4365.

561 F.Supp. 1274 (1983)

NALCO CHEMICAL COMPANY AND SUBSIDIARIES, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Illinois, E.D.

February 18, 1983.

Attorney(s) appearing for the Case

David S. Gibbons, Chadwell & Kayser, Ltd., Chicago, Ill., for plaintiffs.

D. Patrick Mullarkey, Dennis M. Donohue, Tax Div., Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM OPINION AND ORDER

GETZENDANNER, District Judge:

This tax refund litigation concerns the deductibility of corporate payments to a nearly wholly-owned foreign subsidiary under the terms of an indemnification pledge. By agreement of the parties, trial has been held on stipulated facts and exhibits.1 The memorandum which follows constitutes the court's findings of fact and conclusions of law.

I. Facts

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