American Mutual Life Insurance Company and Subsidiaries v. United States of America, the Stock Company Information Group, Amicus Curiae

MORRIS SHEPPARD ARNOLD, Circuit Judge.

The issue in this case is whether Congress intended to give mutual life insurance companies so-called dividend deductions greater than their dividends in any given year. The court concludes that Congress did not so intend, and therefore reverses the judgment of the district court.

I

Appellee American Mutual Life Insurance (“AMLI”) is a mutual life insurance company. AMLI sued the government for a tax refund, claiming that the Internal Revenue Service improperly calculated its income deductions for the year 1986. The district court granted summary judgment…