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  5. 670 F.Supp. 1454 (1986)
 

TRANSAMERICA CORP. v. U.S.

Nos. C 84-0877 TEH, C 85-2543 TEH.

670 F.Supp. 1454 (1986)

TRANSAMERICA CORPORATION, for itself and for all members of the Affiliated Group, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. California.

November 5, 1986.

Attorney(s) appearing for the Case

Cameron W. Wolfe, Jr., W. Reece Bader, Orrick, Herrington & Sutcliffe, San Francisco, Cal., Alexander F. Wiles, Irell & Manella, Los Angeles, Cal., for plaintiff.

U.S. Attorney's Office, Joseph P. Russoniello, Chief, Jay Weill, Asst. U.S. Atty., Chief, Tax Div., San Francisco, Cal., Edward Meese, Atty. Gen., Dept. of Justice, Washington, D.C., for defendant.

ORDER

THELTON E. HENDERSON, District Judge.

This matter comes before the court on cross-motions for summary judgment on plaintiff's claim for a tax refund for the years 1971 through 1974. Few, if any, facts are in dispute. The sole question for the court to determine is whether plaintiff was entitled to include in its basis for motion picture films in the years in question the estimated future participation and residual payments to be made to the films'...

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