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BARNES GROUP, INC. v. U.S.

Civ. No. H-84-1008(MJB).

697 F.Supp. 591 (1988)

BARNES GROUP, INC. v. UNITED STATES of America.

United States District Court, D. Connecticut.

August 29, 1988.

Attorney(s) appearing for the Case

Everett E. Newton, John C. Yavis, Jr., H. Kennedy Hudner, Murtha, Cullina, Richter & Pinney, Hartford, Conn., for plaintiff.

Leslie Ohta, Asst. U.S. Atty., New Haven, Conn., Jerome A. Busch, Terri E. Schapiro, Tax Div., U.S. Dept. of Justice, Deborah S. Meland, Joseph Cammarata, U.S. Dept. of Justice, Washington, D.C., for defendant.

RULING ON CROSS MOTIONS FOR SUMMARY JUDGMENT

BLUMENFELD, Senior District Judge.

I. Introduction

This suit was brought by a corporate taxpayer, Barnes Group, Inc. ("Barnes"), seeking to recover deficiencies paid with respect to certain deductions disallowed by the Internal Revenue Service ("the government") for the 1978 and 1979 tax years. The dispute involves the tax treatment of two entirely separate series of transactions entered into by Barnes...

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