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FIRST M & F CORP. v. U.S.

No. EC88-190-S-D.

767 F.Supp. 792 (1991)

FIRST M & F CORPORATION, Plaintiff, v. UNITED STATES of America, Defendant.

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

July 2, 1991.

Attorney(s) appearing for the Case

Jack D. Warren, Butler, Snow, O'Mara, Stevens & Cannada, Jackson, Miss., for plaintiff.

Richard F. Mitchell, Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

OPINION

SENTER, Chief Judge.

OPINION

This suit involves an attempt by the plaintiff to recover amounts which it has paid to the Internal Revenue Service after certain deductions it took for tax years 1982, 1983, and 1984 were disallowed. The case presents the classic debt/equity question. The case is presently before the court on cross-motions for summary judgment. The facts are largely undisputed.

FACTS

First M & F Corporation...

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