Northwestern Mutual Life Insurance v. United States

OPINION

MARGOLIS, Judge.

This case is before this Court on cross-motions for partial summary judgment,1 submitted with oral argument. The plaintiff, Northwestern Mutual Life Insurance Company, a life insurance company taxable under sections 801-820 of the Internal Revenue Code,2 seeks to recover approximately two million dollars of alleged overpayments of federal income taxes, plus assessed and statutory interest, for the taxable years 1971-76. In each of these years, the plaintiff paid state income or excise taxes to Florida, Illinois, Minnesota and New York. Subsequently, in computing its…