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At issue was whether plaintiffs were entitled to a refund under 26 U.S.C.S. § 7422(a) of taxes paid by a predecessor-in-interest as the parent company of an affiliated group (including a thrift) based upon abandonment loss and amortization deductions. Plaintiffs failed to show, by a preponderance of the evidence, that their FMV determinations for regulatory accounting purposes (RAP) rights, branching rights, and other intangible assets that the thrift acquired through supervisory mergers were reliable. While plaintiffs did not have to determine the value of those assets to an absolute certainty, they had to put forward sufficient evidence for the court to make a reasonable approximation of value. As they failed to do so, they similarly did not establish the thrift’s cost basis in the assets to a reasonable degree of certainty for purposes of pursuing their tax refund claim. The court dismissed the complaint with prejudice.