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Reynolds Metal Co. v. United States

United States District Court for the Eastern District of Virginia
389 F. Supp. 2d 692 (2005)


Facts

From 1940 to 1987, Reynolds Metal Company (Reynolds) (plaintiff) properly disposed of waste byproducts in accordance with industry standards and current law. Later, under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Reynolds was forced to redispose of its waste and to remediate contaminated areas from its previous years of operation. Reynolds paid more than $110 million from 1992 to 1995 to comply with CERCLA. Reynolds was entitled to deduct the payments for CERCLA as a business expense. However, tax rates were lower from 1992 to 1995 than they had been in the period of 47 years between 1940 and 1987. Reynolds filed suit against the United States government (government) (defendant), seeking a tax refund for an overpayment of taxes from 1940 to 1987. Reynolds argued that it should have been able to deduct its CERCLA payments in those years. Both parties filed motions for partial summary judgment.

Rule of Law

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Issue

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Holding and Reasoning (Spencer, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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