Northern Life Insurance Company v. United States of America, Northern Life Insurance Company, Plaintiff-Cross v. United States of America, Defendant-Cross

685 F.2d 277 82-2 USTC P 9560 NORTHERN LIFE INSURANCE COMPANY, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant. NORTHERN LIFE INSURANCE COMPANY, Plaintiff-Cross Appellant, v. UNITED STATES of America, Defendant-Cross Appellee. Nos. 81-3253, 81-3266. United States Court of Appeals, Ninth Circuit. Argued and Submitted June 9, 1982. Decided Aug. 24, 1982. Mitchell Olejko, Davis, Wright, Todd, Riese & Jones, Seattle, Wash., for Northern Life. David I. Pincus, Washington, D. C., argued for United States; Michael L. Paup, Chief, App. Section, Washington, D. C., on brief. On Appeal from the United States District Court for the Western District of Washington. Before WRIGHT, SKOPIL and ALARCON, Circuit Judges. EUGENE A. WRIGHT, Circuit Judge: 1 Northern Life Insurance Company (Northern Life) seeks reversal of the district court's denial of two of its refund claims. The United States (IRS) seeks reversal of the one refund claim granted Northern Life. We must decide: (1) whether prepaid interest accrues when it is paid, or when it is earned; (2) whether Northern Life filed a timely refund claim for 1968; and (3) whether Northern Life received taxable income when it…