Principal Life Insurance Company and Subsidiaries v. United States

OPINION

ALLEGRA, Judge:

“[T]he tax could not be escaped by anticipatory arranyements and contracts however skillfully devised ... by which the fruits are attributed to a different tree from that on which they yrew.” 1

Before the court, on cross-motions for partial summary judgment, is the next leg of this complex tax refund suit. 2 At issue is the tax treatment of two distinct, but structurally-similar, series of investments made by Principal Life Insurance Company and Subsidiaries (PLIC). Eight of these investments related to so-called “custodial share receipts” or “CSRs,” while three others…