Alcoa, Inc. v. United States

509 F.3d 173 (2007)

From our private database of 46,100+ case briefs, written and edited by humans—never with AI.

Alcoa, Inc. v. United States

United States Court of Appeals for the Third Circuit
509 F.3d 173 (2007)

JR

Facts

Alcoa, Inc. (plaintiff) was an aluminum and aluminum-products producer. From 1940 to 1987, Alcoa disposed of waste byproducts produced in its ordinary course of business. Alcoa alleged that during these years, for tax purposes, it included the disposal costs in its costs-of-goods-sold (COGS) calculations, thus excluding those costs from its gross income. In 1993, Alcoa’s disposal costs increased significantly due to new environmental laws. On its 1993 tax return, Alcoa therefore deducted the disposal costs from its taxable income as business expenses. The Internal Revenue Service (IRS) (defendant) did not contest Alcoa’s deductions. However, when Alcoa requested a refund for disposal costs incurred from 1940 to 1987 pursuant to Internal Revenue Code § 1341, the IRS declined. Under § 1341, a taxpayer can take a deduction for returning funds he rightfully received in a previous tax year. Alcoa filed a refund claim in district court. The IRS asserted that Alcoa could not claim a refund for money not spent on disposal costs because the costs had been incurred in Alcoa’s normal course of business and that Alcoa had not restored the unspent funds to the funds’ rightful owner because one did not exist, thereby disqualifying the funds for consideration under § 1341. Alcoa countered that its COGS were understated and its gross income was overstated, entitling it to a refund. The district court sided with the IRS, and Alcoa appealed.

Rule of Law

Issue

Holding and Reasoning (Roth, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 745,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 745,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,100 briefs, keyed to 987 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 745,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,100 briefs - keyed to 987 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership