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C. I. R. v. UNION MUTUAL INSURANCE COMPANY OF PROVIDENCE

No. 6922.

386 F.2d 974 (1967)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. UNION MUTUAL INSURANCE COMPANY OF PROVIDENCE, Respondent.

United States Court of Appeals First Circuit.

December 5, 1967.

Attorney(s) appearing for the Case

Thomas L. Stapleton, Atty., Dept. of Justice, with whom Mitchell Rogovin, Asst. Atty. Gen., and Lee A. Jackson and Gilbert E. Andrews, Attys., Dept. of Justice, were on brief, for petitioner.

Carl J. Marold, Boston, Mass., with whom James R. Hopkins and Herrick, Smith, Donald, Farley & Ketchum, Boston, Mass., were on brief, for respondent.

Before ALDRICH, Chief Judge, McENTEE and COFFIN, Circuit Judges.

COFFIN, Circuit Judge.

The Commissioner of Internal Revenue petitions for review of a Tax Court decision which held that the Commissioner erroneously disallowed certain deductions as interest on indebtedness, for the years 1957 through 1962 within the meaning of section 822(c) (5) of the Internal Revenue Code of 1954. The question turns on the nature, for income tax purposes, of semi-annual payments to holders of "Guaranty Fund Certificates" issued by a mutual insurance...

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