John A. Greene, Receiver for the Great Global Assurance Company v. United States

GAJARSA, Circuit Judge.

This is the second appeal in an action by John Greene (“Greene”), receiver in liquidation for Great Global Assurance Company (“Great Global”), to recover $699,849 in tax and interest paid by Great Global in 1990 for the tax year 1983. On March 27, 1996, Greene filed for a refund in the United States Court of Federal Claims (“CFC”), arguing that the tax was improperly assessed, and in the alternative that Great Global’s policyholder and guaranty fund claimants were entitled to priority of distribution over the Internal Revenue Service (“IRS”). Greene intended to…