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

No. 2014-5019.

782 F.3d 1354 (2015)

MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANY, on its own behalf, and Massachusetts Mutual Life Insurance Company, as successor to Connecticut Mutual Life Insurance Company, Plaintiff-Appellee v. UNITED STATES, Defendant-Appellant.

United States Court of Appeals, Federal Circuit.

April 9, 2015.

Attorney(s) appearing for the Case

Bernard John Williams, Jr., Skadden, Arps, Slate, Meagher & Flom LLP, Washington, DC, argued for plaintiff-appellee. Also represented by David W. Foster,   Alan J. Swirski,   Paul McLaughlin.

Arthur Thomas Catterall, Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellant. Also represented by Robert William Metzler,   Tamara W. Ashford.

Before LOURIE, MOORE, and O'MALLEY, Circuit Judges.

The government appeals a judgment of the United States Court of Federal Claims in favor of Massachusetts Mutual Life Insurance Company ("MassMutual") and Connecticut Mutual Life Insurance Company ("ConnMutual"). The Court of Federal Claims ruled that MassMutual and ConnMutual were...

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