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PHILADELPHIA & READING CORP. v. U.S.

Civ. A. No. 83-823-CMW.

738 F.Supp. 143 (1990)

PHILADELPHIA & READING CORPORATION, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Delaware.

May 31, 1990.

Attorney(s) appearing for the Case

Edward B. Maxwell, II of Young, Conaway, Stargatt & Taylor, Wilmington, Del. (Frederic L. Hahn, Glen H. Kanwit and David B. Goroff of Hopkins & Sutter, Chicago, Ill., of counsel), for plaintiff.

William C. Carpenter, Jr., U.S. Atty. for Del., and Kent A. Jordon, Asst. U.S. Atty. for Del. (James I.K. Knapp, Acting Asst. Atty. Gen., Edward J. Snyder and Donald J. Gavin, Attys. for Tax Div., Dept. of Justice, Washington, D.C., of counsel), for defendant.

OPINION

CALEB M. WRIGHT, Senior District Judge.

This tax refund suit now comes before this Court after a long and tedious history.1 Plaintiff Philadelphia & Reading Corporation ("P & R") filed its complaint on November 22, 1983 to obtain a refund from the United States Internal Revenue Service (the "IRS") of approximately $10.1 million of assessed taxes plus interest and penalties.2 After...

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