Ohio National Life Insurance v. United States

ORDER

WIESE, Judge.(i) Granting Defendant’s Motion for

Summary Judgment

and(ii) Directing Dismissal of Complaint

This is a suit for refund of $471,172 in federal income taxes and assessed interest for the years 1974 and 1975. The matter in dispute, presented here through cross-motions for summary judgment, concerns the *478proper tax treatment for certain expenses associated with plaintiffs life insurance business. Specifically, the question is whether amounts plaintiff paid for state franchise taxes, state audit examination fees and policy renewal commissions are chargeable, in part, against gross…