United States Court of Claims October 22, 1987, No. 356-85T (U.S. Shelter Corp. v. United States)

OPINION

NAPIER, Judge.

This is a tax refund case involving the “principal purpose” provision of Section 269 of the Internal Revenue Code of 1954,1 and the effect of that section on plaintiff’s federal income tax liability for the years 1979 and 1980.

Plaintiff, U.S.