United States Federal Circuit

Rejection of a mutual life insurance corporation's claim for a refund of income taxes paid was proper, based on the trial court's finding that Internal Revenue Code section 811(d) requires reserves for excess interest guaranteed beyond the end of the current year to be excluded only from tax reserves, and not from statutory reserves.

Appellate Information

• Decided 07/01/2002
• Published 07/01/2002

Judges

• BRYSON, Circuit Judge., Before MICHEL, BRYSON, and LINN, Circuit Judges.

Court

• United States Federal Circuit

Counsel

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


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