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PRINCIPAL LIFE INSURANCE COMPANY v. U.S.

No. 07-0006T.

PRINCIPAL LIFE INSURANCE COMPANY AND SUBSIDIARIES Plaintiff, v. THE UNITED STATES, Defendant.

United States Court of Federal Claims.

November 12, 2010.

Attorney(s) appearing for the Case

Bruce Graves, Brown Winick, P.L.C., Des Moines, Iowa, for plaintiff.

Bart Duncan Jeffress, United States Department of Justice, Washington, D.C., with whom was Acting Assistant Attorney General John A. DiCicco, for defendant.

OPINION

FRANCIS M. ALLEGRA, District Judge.

"The procedural aspects of the tax laws are of overriding importance in many controversies," one commentator has noted, "eclipsing or making moot substantive issues such as the allowance of deductions or credits, recognition or deferral of income, and methods of accounting." Theodore D. Peyser, 627-3rd Tax Management Portfolio, "Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation" at...

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