CAMPBELL v. GREAT NATIONAL LIFE INSURANCE COMPANY

No. 15005.

219 F.2d 693 (1955)

Ellis CAMPBELL, Jr., Director of Internal Revenue for the Second Collection District of Texas, Appellant, v. GREAT NATIONAL LIFE INSURANCE COMPANY, Appellee.

United States Court of Appeals, Fifth Circuit.

February 18, 1955.


Attorney(s) appearing for the Case

Grant W. Wiprud, Tax Div., Dept. of Justice, Washington, D. C., H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst. to the Atty. Gen., John C. Ford, Asst. U. S. Atty., Dallas, Tex., Hilbert P. Zarky, Sp. Asst. to the Atty. Gen., Heard L. Floore, U. S. Atty., Fort Worth, Tex., for appellant.

Webster Atwell, Dallas, Tex., Walton Grayson, III, Dallas, Tex., of counsel, for appellee.

Before HUTCHESON, Chief Judge, and BORAH and RIVES, Circuit Judges.


BORAH, Circuit Judge.

This case presents the question whether royalties are "rents" within the definition of the gross income of life insurance companies as set forth in Section 201(c) (1) of the Internal Revenue Code.1

The appellee here, the Great National Life Insurance Company, was during the period hereinafter mentioned, a life insurance company as defined in Section 201(b) of the Internal Revenue Code. In the conduct of its...

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