PPL Corp. & Subsidiaries v. Comm'r, 2010 U.S. Tax Ct. LEXIS 31 (T.C. Sept. 9, 2010)

The IRS had declared a deficiency in 1997 federal income tax paid by PPL Corporation, the common parent of a group filing consolidated returns, denying its refund claim. At issue inter alia was the correctness of an IRS claim that a "windfall tax" paid by PPL's indirect United Kingdom subsidiary...