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PRINCIPAL MUT. LIFE INS. & SUBSIDIARIES v. U.S.

No. 01-5036.

295 F.3d 1241 (2002)

PRINCIPAL MUTUAL LIFE INSURANCE COMPANY AND SUBSIDIARIES (now known as Principal Life Insurance Company and Subsidiaries), Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Rehearing Denied: August 27, 2002.

Attorney(s) appearing for the Case

Bruce Graves, Brown, Winick, Graves, Gross, Baskerville and Schoenebaum, PLC, of Des Moines, IA, argued for plaintiff-appellant.

Edward T. Perelmuter, Attorney, Tax Division, Department of Justice, of Washington, DC, argued for defendant-appellee. With him on the brief was Claire Fallon, Acting Assistant Attorney General; and David I. Pincus, Attorney.

Before MICHEL, BRYSON, and LINN, Circuit Judges.

Rehearing En Banc Denied: August 27, 2002.

BRYSON, Circuit Judge.

In this complex federal tax case, the taxpayer, Principal Mutual Life Insurance Company and Subsidiaries ("Principal"), seeks a refund of income taxes that it paid for taxable years 1984, 1985, and 1986. The United States Court of Federal Claims rejected Principal's claim in a thorough and lucid opinion. We have carefully reviewed Principal's detailed critique of the trial court's opinion and...

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