Travelers Insurance v. United States

OPINION

SMITH, Chief Judge.

These consolidated cases, involving claims for refund of $9,965,157.00 in income taxes and interest for the tax years 1975 through 1980, are before the court on the parties’ cross-motions for partial summary judgment. The pending motions involve the determination of plaintiff’s foreign source taxable income for purposes of its allowable credit for taxes paid to the government of Indonesia for the years 1975 through 1980. Plaintiff contends that defendant improperly computed its foreign investment income by reference to the life insurance company income tax provisions…