ORDER
DAVID C. GODBEY, District Judge.
This matter came on for trial before the Court on March 31, 2009 through April 3, 2009. This Order constitutes the Court's findings of fact and conclusions of law.
I. INTRODUCTION
This is a tax refund suit. Trinity Industries, Inc. ("Trinity") seeks a refund for certain qualified research expenditure ("QRE") tax credits it claims were wrongly disallowed for its tax years ending in March of 1994...
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