MASSACHUSETTS MUT. LIFE INS. CO. v. U.S.

Appeal No. 84-1526.

761 F.2d 666 (1985)

MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY, Appellant, v. The UNITED STATES, Appellee.

United States Court of Appeals, Federal Circuit.

May 7, 1985.


Attorney(s) appearing for the Case

Francis Gregory, Jr., Sutherland, Asbill & Brennan, of Washington, D.C., for appellant. With him on brief were James V. Jeffernan, Gordon O. Pehrson, Jr. and Michael A. Bell, Washington, D.C.

Stephen P. Horvat, Jr. and Margaret Sperry, Springfield, Mass., of counsel.

Gary Allen, Tax Div., U.S. Dept. of Justice, of Washington, D.C., for appellee. With him on brief were Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Nancy Morgan, Washington, D.C.

Before DAVIS, BALDWIN and NIES, Circuit Judges.


DAVIS, Circuit Judge.

Massachusetts Mutual Life Insurance Co. (Mutual) appeals from a decision of the United States Claims Court, Margolis, J., (5 Cl.Ct. 581 (1984)) granting the Government's motion for summary judgment. At issue is the proper treatment of a particular bad debt loss under the special provisions relating to the taxation of life insurance companies in the Internal Revenue Code of 1954, as amended, 26 U.S.C. §§ 801-820 (1982).

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