Massachusetts Mutual Life Insurance Company v. The United States

DAVIS, Circuit Judge.

Massachusetts Mutual Life Insurance Co. (Mutual) appeals from a decision of the United States Claims Court, Margolis, J, (5 Cl.Ct. 581 (1984)) granting the Government’s motion for summary judgment. At issue is the proper treatment of a particular bad debt loss under the special provisions relating to the taxation of life insurance companies in the Internal Revenue Code of 1954, as amended, 26 U.S.C. §§ 801-820 (1982). 1 We affirm.

I

In 1950, Mutual loaned $2,500,000 to Texas Consolidated Oils (TCO) as part of a $15,100,000 loan package. Of that sum, the Reconstruction…