United States Federal Circuit

For taxation of life insurance companies, policyholders' share of income is properly excluded from "taxable income" for purposes of computing a limitation on foreign tax credit in Internal Revenue Code section 904.

Appellate Information

• Decided 09/16/2002
• Published 09/16/2002

Judges

• DYK, Circuit Judge., Before SCHALL, DYK, and PROST, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellees:
  
• Peter H. Winslow,Scribner, Hall & Thompson, LLP, of Washington, DC, argued for plaintiff-appellee., Edward T. Perelmuter, Attorney, Tax Division, Department of Justice, of Washington, DC, argued for defendant-appellant.   With him on the brief were Eileen J. O'Connor, Assistant Attorney General;  David English Carmack, and David I. Pincus, Attorneys.