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AMP INC. AND CONSOL. SUBSIDIARIES v. U.S.

No. 98-5083.

185 F.3d 1333 (1999)

AMP INCORPORATED AND CONSOLIDATED SUBSIDIARIES, Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

August 2, 1999.

Attorney(s) appearing for the Case

Jeffrey M. O'Donnell, Baker & McKenzie, of Chicago, Illinois, argued for plaintiff-appellant. With him on the brief were Robert J. Cunningham and Karen A. Kuenster. Of counsel was John D. McDonald.

Kenneth W. Rosenberg, Attorney, Tax Division, Department of Justice, of Washington, DC, argued for defendant-appellee. With him on the brief were Loretta C. Argrett, Assistant Attorney General, and David English Carmack, Attorney.

Before CLEVENGER, Circuit Judge, ARCHER, Senior Circuit Judge, and GAJARSA, Circuit Judge.

ARCHER, Senior Circuit Judge.

DECISION

AMP Incorporated and Consolidated Subsidiaries (AMP) appeals the summary judgment of the Court of Federal Claims in favor of the United States (the government). See AMP Inc. and Consol. Subsidiaries v. United States, 40 Fed.Cl. 172 (1998) (AMP I).1 The court held that AMP is not entitled to a redetermination of the foreign tax credit claimed in its 1981 and 1982 tax returns...

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