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CREDIT LIFE INS. CO. v. U.S.

No. 91-5028.

948 F.2d 723 (1991)

The CREDIT LIFE INSURANCE COMPANY, Plaintiff-Appellee, v. The UNITED STATES, Defendant-Appellant.

United States Court of Appeals, Federal Circuit.

Suggestion for Rehearing Declined January 22, 1992.

Attorney(s) appearing for the Case

Peter H. Winslow, Scribner, Hall & Thompson, Washington, D.C., argued for plaintiff-appellee. With him on the brief was E.P. Baker, of counsel.

Robert W. Metzler, Attorney, Dept. of Justice, Washington, D.C., argued for defendant-appellant. With him on the brief were Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen and David I. Pincus.

Before NEWMAN, MICHEL, and PLAGER, Circuit Judges.

Suggestion for Rehearing In Banc Declined January 22, 1992.

MICHEL, Circuit Judge.

The government appeals the United States Claims Court's grant of summary judgment in favor of The Credit Life Insurance Company ("Credit Life" or "taxpayer") in its suit for a partial refund of income taxes paid. Credit Life Ins. Co. v. United States, No. 585-84T (Cl.Ct. Oct. 17, 1990). The Claims Court erred in concluding that in claiming a bad debt deduction, taxpayer...

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