John Hancock Financial Services, Inc., and John Hancock Life Insurance Company (Formerly John Hancock Mutual Life Insurance Company) v. United States

BRYSON, Circuit Judge.

John Hancock Financial Services, Inc., and John Hancock Life Insurance Company (collectively, “Hancock”) appeal from the decision of the United States Court of Federal Claims denying a claim for a tax refund. Hancock invoked the “tax benefit rule” in an effort to obtain, for certain years, tax benefits that it was unable to use in earlier years. In a thorough opinion, the trial judge held that the tax benefit rule did not apply in the context of this case. John Hancock Fin. Servs., Inc. v. United States, 57 Fed.Cl. 643 (Fed.Cl.2003). We agree that the tax benefit rule is…