Massachusetts Mutual Life Insurance v. United States

OPINION

MARGOLIS, Judge.

Plaintiff, Massachusetts Mutual Life Insurance Company, a life insurance company taxable under section 802 of the Internal Revenue Code,1 seeks to recover alleged overpayments of federal income taxes and assessed interest for the taxable years 1960-61 and 1963-66 in the net amount of about 1.2 million dollars. In *583each of these years, certain loans which had been made by plaintiff in the ordinary course of its investment operations proved to be uncollectible in whole or in part. The issue presented is whether, as plaintiff contends, plaintiff can deduct these bad debts…