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PRUDENTIAL INSURANCE COMPANY OF AMERICA v. UNITED STATES

Nos. 202-63, 247-63 — 252-63.

337 F.2d 651 (1964)

The PRUDENTIAL INSURANCE COMPANY OF AMERICA v. The UNITED STATES.

United States Court of Claims.

October 16, 1964.

Attorney(s) appearing for the Case

Francis A. Goodhue, Jr., New York City, for plaintiff. Arthur E. Schmauder, Frank G. Koch, Newark, N. J., John H. Perkins, Jr., Peter J. Sturtevant, Dewey, Ballantine, Bushby, Palmer & Wood, New York City, of counsel.

Martin B. Cowan, Washington, D. C., with whom was Asst. Atty. Gen. Louis F. Oberdorfer, for defendant. C. Moxley Featherston, Lyle M. Turner, Philip R. Miller and Thomas A. Troyer, Washington, D. C., on the brief.

Before JONES, Senior Judge, WHITAKER, Senior Judge, and LARAMORE, DURFEE and DAVIS, Judges.

DURFEE, Judge.

These are seven suits by the taxpayer, a mutual life insurance company, incorporated in the State of New Jersey, seeking recovery of alleged overpayments of Federal income taxes. The actions have been consolidated by order of the court. Both parties have moved for partial summary judgment on one of the issues involved, i. e., whether or not plaintiff is entitled to a foreign tax credit under sections 131(a...

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