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LEGAL SECURITY LIFE INSURANCE CO. v. UNITED STATES

No. 19396.

302 F.2d 315 (1962)

LEGAL SECURITY LIFE INSURANCE COMPANY, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Fifth Circuit.

May 2, 1962.

Attorney(s) appearing for the Case

Douglas E. Bergman, Sylvan Tobolowsky, Dallas, Tex., for appellant.

Barefoot Sanders, U. S. Atty., Dallas, Tex., Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Burt J. Abrams, Michael A. Mulroney, Attys., Dept. of Justice, Washington, D. C., for appellee.

Before TUTTLE, Chief Judge, and HUTCHESON and WISDOM, Circuit Judges.

TUTTLE, Chief Judge.

The question raised by this appeal is whether liability for a documentary stamp tax arose as upon a "transfer * * * of rights to * * * receive" shares of stock in a corporation when Legal Security Life Insurance Company issued all of its outstanding capital stock on organization directly to the stockholders of Legal Reserve Insurance Trust in return for the transfer by Legal Reserve Insurance Trust of all of its assets representing the net amount...

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