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METROPOLITAN LIFE INSURANCE COMPANY v. UNITED STATES

Nos. 79-59, 444-60, 361-64.

375 F.2d 835 (1967)

METROPOLITAN LIFE INSURANCE COMPANY v. The UNITED STATES.

United States Court of Claims.

April 14, 1967.

Attorney(s) appearing for the Case

Thomas N. Tarleau, New York City, attorney of record, for plaintiff; George E. Walton, Bernard G. Hildebrand, New York City, Robert Holt Myers, Williams, Myers & Quiggle, Washington, D. C., Laurence G. Bodkin, Jr., and Willkie, Farr, Gallagher, Walton & FitzGibbon, New York City, of counsel.

Mildred L. Seidman, Washington, D. C., with whom was Asst. Atty. Gen. Mitchell Rogovin, for defendant; Richard M. Roberts, Lyle M. Turner, Philip R. Miller, and Martin B. Cowan, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON and NICHOLS, Judges.

ON PLAINTIFF'S MOTIONS FOR SUMMARY JUDGMENT AND DEFENDANT'S CROSS-MOTIONS FOR SUMMARY JUDGMENT

DAVIS, Judge.

This is the fourth time in as many years that we are called upon to consider the application of the foreign tax credit (Sec. 131 of the Internal Revenue Code of 1939; Sections 901, 903 of the Internal Revenue Code of 1954) to the Canadian premiums taxes on mutual life insurance companies. See Prudential Ins...

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