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SERVICE LIFE INSURANCE COMPANY v. UNITED STATES

No. 16628.

293 F.2d 72 (1961)

SERVICE LIFE INSURANCE COMPANY, a Corporation, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Eighth Circuit.

July 17, 1961.

Attorney(s) appearing for the Case

Joseph T. Votava, Omaha, Neb., Beber & Richards, Omaha, Neb., on the brief, for appellant.

William A. Friedlander, Attorney, Tax Division, Dept. of Justice, Washington, D. C., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and A. F. Prescott, Attorneys, Dept. of Justice, Washington, D. C., and William C. Spire, U. S. Atty., and Thomas J. Skutt, Asst. U. S. Atty., Omaha, Neb., on brief, for appellee.

Before JOHNSEN, Chief Judge, and WOODROUGH and MATTHES, Circuit Judges.

MATTHES, Circuit Judge.

The Service Life Insurance Company, hereinafter referred to as plaintiff, instituted this statutory action for the purpose of recovering a refund of income taxes which it paid pursuant to deficiency assessments for the years 1949, 1950, 1952 and 1953. The deficiencies arose from disallowance of deductions for certain sums paid as interest on borrowed funds.

Plaintiff was incorporated under the insurance laws of the State of Nebraska...

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