CUNA Mutual Life Insurance v. United States

OPINION & ORDER

HODGES, Judge.

Plaintiff CUNA Mutual Life Insurance Company seeks a refund of an alleged federal tax overpayment. The United States contends that the Internal Revenue Code and the Treasury regulations interpreting the Code do not entitle plaintiff to a refund. We must defer to the interpretation of the Code provided by defendant’s regulation absent circumstances not present here. Plaintiff is not entitled to a refund under that interpretation.

BACKGROUND

I

Plaintiff claims entitlement to policyholder dividend deductions totaling $33,379,532 with *661respect to its taxable year 1986.…