Court of Appeals for the Federal Circuit February 4, 1987, Appeal 86-992 (The E.F. Hutton Group, Inc. v. The United States)

DAVIS, Circuit Judge.

This tax refund case comes to us from the United States Claims Court which held

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for the Government on cross-motions for summary judgment. We affirm.

I.

Background

The hard facts were stipulated and are not in dispute. In 1974 and 1975, plaintiff-appellant, taxpayer E.F. Hutton Group, Inc., filed consolidated income tax returns as the parent company of E.F.