Legal Opinion
Metropolitan Life Insurance Company v. The United States
United States Court of Claims
Decided April 14, 1967No. 79-59, 444-60, 361-64PublishedCited by 5 opinions
1Opinion of the Court
ON PLAINTIFF’S MOTIONS FOR SUMMARY JUDGMENT AND DEFENDANT’S CROSS-MOTIONS FOR SUMMARY JUDGMENT
DAVIS, Judge.
This is the fourth time in as many years that we are called upon to consider the application of the foreign tax credit (Sec. 131 of the Internal Revenue Code of 1939; Sections 901, 903 of the Internal Revenue Code of 1954) to the Canadian premiums taxes on mutual life insurance companies. See Prudential Ins. Co. of America v. United States, 319 F.2d 161, 162 Ct.Cl. 55 (1963); Prudential Ins. Co. of America v. United States, 337 F.2d 651, 167 Ct.Cl. 598 (1964), pending on petition for a…
2Cases cited14 opinions
- Towne v. EisnerSupreme Court of the United States · 1918
- American Chicle Co. v. United StatesSupreme Court of the United States · 1942
- Waterman Steamship Corp. v. United StatesSupreme Court of the United States · 1965
- Marsman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- The Prudential Insurance Company of America v. The United StatesUnited States Court of Claims · 1963
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3Cited by5 opinions
- Missouri Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1968
- United States v. Occidental Life Insurance Company of California, a California CorporationCourt of Appeals for the Ninth Circuit · 1967
- Allstate Insurance Company v. The United StatesUnited States Court of Claims · 1969
- International Telephone & Telegraph Corp. v. United StatesUnited States Court of Claims · 1979
- Allstate Insurance Company v. The United StatesUnited States Court of Claims · 1969