RADER, Chief Judge.
The United States Court of Federal Claims granted the United States' motion for summary judgment against Dominion Resources, Inc. See Dominion Res., Inc. v. United States, 97 Fed.Cl. 239 (2011). This case presents an issue of first impression for any appellate court. The CFC held that Treasury Regulation § 1.263A-11(e)(1)(ii)(B) is a permissible construction of the statute I.R.C. § 263A. Because the associated property rule in...
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