This appeal is from a decision of the United States Claims Court, holding that certain insurance company state income taxes are deductible under 26 U.S.C. § 804(c), and granting plaintiffs motion for partial summary judgment.

The parties’ arguments are thoroughly treated in the lower court’s opinion in consolidated cases numbered 441-80T and 125-82T, dated March 7, 1985, 7 Cl.Ct. 501 (1985). We affirm on the basis of that opinion.

AFFIRMED.