The IRS assessed additional income and FICA taxes for the value of the meals for the 2014, 2015, 2018, and 2019 tax years. Northwestern Mutual paid the disputed taxes and underpayment interest, then filed timely claims for refunds, which the IRS disallowed. The company is now seeking a refund of $18,900,414 in taxes and $4,146,680 in underpayment interest, as well as overpayment interest on any awarded sums, and a judicial declaration regarding the application of Section 119 to its meal program.