Dominion Resources, Inc. v. United States
United States Court of Appeals for the Federal Circuit
681 F.3d 1313 (2012)
- Written by Rose VanHofwegen, JD
Facts
When Dominion Resources, Inc. (Dominion) (plaintiff) replaced coal burners in two of its electric power plants, it temporarily removed the units from service. Meanwhile, Dominion continued incurring interest on debt unrelated to the improvements and deducted some of that interest on its corporate tax return. The Internal Revenue Service (IRS) (defendant) disagreed with Dominion’s deduction and required Dominion to capitalize instead of deduct $3.3 million of interest under a treasury regulation. The parties agreed to a settlement allowing Dominion to deduct half and capitalize half of the disputed amount, but Dominion petitioned asserting the regulation was invalid and the entire amount deductible, seeking a refund of about $300,000. The Federal Claims Court granted the IRS summary judgment. Dominion appealed.
Rule of Law
Issue
Holding and Reasoning (Rader, C.J.)
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