NORTHWESTERN MUTUAL LIFE INS. CO., v. U.S

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Docket Number

Appeal Nos. 85-2755, 85-2810.

Attorney(S)

David Pincus, Tax Div., Dept. of Justice, Washington, D.C., argued for appellant/cross-appellee. With him on brief were Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup and Gary R. Allen. George R. Abramowitz, Sutherland, Asbill Brennan, Washington, D.C., argued for appellee/cross-appellant. With him on brief were Francis M. Gregory, Jr. and Michael R. Miles, of counsel. Michael J. Jones and John M. Bremer, Northwestern Mut. Life Ins. Co., Milwaukee, Wis., of counsel.

Judges

Phillip Benjamin Baldwin

Acts

Internal Revenue Code — Income Taxes — Normal Taxes And Surtaxes — Insurance Companies — Life Insurance Companies — Life Insurance Deductions — Life Insurance Deductions

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Cites

Citation Codes

Equivalent Citations

citation codes

Docket Number

Appeal Nos. 85-2755, 85-2810.

Attorney(S)

David Pincus, Tax Div., Dept. of Justice, Washington, D.C., argued for appellant/cross-appellee. With him on brief were Roger M. Olsen, Acting Asst. Atty. Gen., Michael L. Paup and Gary R. Allen. George R. Abramowitz, Sutherland, Asbill Brennan, Washington, D.C., argued for appellee/cross-appellant. With him on brief were Francis M. Gregory, Jr. and Michael R. Miles, of counsel. Michael J. Jones and John M. Bremer, Northwestern Mut. Life Ins. Co., Milwaukee, Wis., of counsel.

Judges

Phillip Benjamin Baldwin

Acts

Internal Revenue Code — Income Taxes — Normal Taxes And Surtaxes — Insurance Companies — Life Insurance Companies — Life Insurance Deductions — Life Insurance Deductions

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THE NORTHWESTERN MUTUAL LIFE INSURANCE COMPANY, APPELLEE/CROSS-APPELLANT, v. THE UNITED STATES, APPELLANT/CROSS-APPELLEE.

BALDWIN, Circuit Judge.

This appeal is from a decision of the United States Claims Court, holding that certain insurance company state income taxes are deductible under 26 U.S.C. § 804(c), and granting plaintiff's motion for partial summary judgment.

The parties' arguments are thoroughly treated in the lower court's opinion in consolidated cases numbered 441-80T and 125-82T, dated March 7, 1985, 7 Cl.Ct. 501 (1985). We affirm on the basis of that opinion.

AFFIRMED.

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THE NORTHWESTERN MUTUAL LIFE INSURANCE COMPANY, APPELLEE/CROSS-APPELLANT, v. THE UNITED STATES, APPELLANT/CROSS-APPELLEE.

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