Travelers Insurance v. United States

OPINION

SMITH, Chief Judge.

This case is before the court on plaintiffs Motion for Partial Summary Judgment and the government’s Cross-Motion for Partial Summary Judgment.1 Plaintiff seeks recovery in the amount of $9,965,157, plus interest for the alleged overpayment of federal taxes during the taxable years 1974 through 1980. Plaintiff claims that its method of translating its profits and losses from Canadian operations into United States dollars clearly reflected income and that the Internal Revenue Service (IRS or Service), in requiring plaintiff to change its method, abused its discretion.…