The FRANKLIN LIFE INSURANCE COMPANY, Plaintiff-Appellee,
v.
UNITED STATES of America, Defendant-Appellant.
United States Court of Appeals Seventh Circuit.https://leagle.com/images/logo.png
July 11, 1968.
As Modified on Denial of Rehearing August 30, 1968.
Attorney(s) appearing for the Case
Mitchell Rogovin, Asst. Atty. Gen., Thomas L. Stapleton, Lee A. Jackson, Meyer Rothwacks, Harry Marselli, Tax Division, U. S. Dept. of Justice, Washington, D. C., Richard E. Eagleton, Springfield, Ill., Gilbert E. Andrews, Atty., Dept. of Justice, Washington, D. C., for appellant.
Louis F. Gillespie, George B. Gillespie, Frederick H. Stone, Springfield, Ill., for appellee; Gillespie, Burke & Gillespie, Springfield, Ill., of counsel.
Fred. C. Scribner, Jr., Thomas C. Thompson, Jr., Washington, D. C., for amicus curiæ.
David A. Sutherland, Washington, D. C., William C. Smith, Bruce A. Coggeshall, Portland, Me., for American Life Convention as amicus curiæ; Scribner, Hall & Casey, Washington, D. C., Pierce, Atwood, Scribner, Allen & McKusick, Portland, Me., William B. Harman, Jr., Washington, D. C., of counsel.
Before CASTLE, Chief Judge, HASTINGS, Circuit Judge, and KNOCH, Senior Circuit Judge.
United States Court of Appeals Seventh Circuit.
CASTLE, Chief Judge.
The United States of America, defendant-appellant, prosecutes this appeal from a judgment in the amount of $1,303,011.88 entered against it in favor of The Franklin Life Insurance Company,1 plaintiff-appellee. The judgment represents a refund of amounts assessed against the taxpayer as income tax deficiencies, and interest thereon, for the calendar years 1958 through 1962. The taxpayer had paid the deficiencies and...
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