NATIONAL LIFE AND ACCIDENT INSURANCE CO. v. UNITED STATES

Civ. A. No. 3304.

244 F.Supp. 135 (1965)

The NATIONAL LIFE AND ACCIDENT INSURANCE COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court Middle District Tennessee, Nashville Division.

As Corrected July 27, 1965.


Attorney(s) appearing for the Case

Walter M. Robinson, Jr., and James R. Tuck, Associate General Counsel, National Life & Accident Ins. Co., Nashville, Tenn., for plaintiff.

George A. Hrdlicka, Tax Division, Department of Justice, Washington, D. C., and James F. Neal, U. S. Atty., Nashville, Tenn., for defendant.


WILLIAM E. MILLER, Chief Judge.

Plaintiff taxpayer qualifies as a life insurance company under provisions of the Internal Revenue Code (Sections 801 et seq. of the 1954 Code) which impose upon such companies a plan of taxation substantially different from that imposed upon individual and corporate taxpayers generally. This action is to recover income taxes alleged to have been erroneously collected under such plan for the tax year 1957. The total recovery sought is...

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