Allstate Insurance Company v. United States

KNOCH, Circuit Judge.

Plaintiff-Appellant, Allstate Insurance ■Company, hereinafter called “Allstate,” brought this action in the United States District Court to secure refund of federal income taxes (plus interest) in a total amount in excess of $3,400,000, allegedly assessed and collected wrongfully for the years 1950, 1952 and 1953. The facts are undisputed (with one not very pertinent ■exception noted below), and the parties ■filed cross motions for summary judgment. The District Court granted defendant’s motion and denied the motion ■of Allstate which took this appeal.

Allstate is a…