Principal Mutual Life Insurance Company and Subsidiaries (Now Known as Principal Life Insurance Company and Subsidiaries) v. United States

BRYSON, Circuit Judge.

In this complex federal tax case, the taxpayer, Principal Mutual Life Insurance Company and Subsidiaries (“Principal”), seeks a refund of income taxes that it paid for taxable years 1984, 1985, and 1986. The United States Court of Federal Claims rejected Principal’s claim in a thorough and lucid opinion. We have carefully reviewed Principal’s detailed critique of the trial court’s opinion and are not persuaded that the trial court erred in construing the pertinent provisions of the Internal Revenue Code. Although the statutory framework is intricate and the language of a…