JEFFERSON STANDARD LIFE INSURANCE COMPANY, Appellee,
v.
UNITED STATES of America, Appellant (two cases).
JEFFERSON STANDARD LIFE INSURANCE COMPANY, Appellant,
v.
UNITED STATES of America, Appellee (two cases).
United States Court of Appeals Fourth Circuit.https://leagle.com/images/logo.png
Argued October 31, 1968.
Decided March 13, 1969.
Attorney(s) appearing for the Case
Fred W. Peel, Washington, D. C., and Wm. J. Adams, Jr., Greensboro, N. C. (Charles G. Powell, Jr., Adams, Kleemeier, Hagan & Hannah, Greensboro, N. C., and Miller & Chevalier, Washington, D. C., on brief), for Jefferson Standard Life Ins. Co.
Thomas L. Stapleton, Atty., Dept. of Justice (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and Gilbert E. Andrews, Attys., Dept. of Justice, and William H. Murdock, U. S. Atty., on brief), for United States.
Fred C. Scribner, Jr., Thomas C. Thompson, Jr., Washington, D. C., William C. Smith, Portland, Me., David A. Sutherland, Washington, D. C., and Bruch A. Coggeshall, Portland, Me., Scribner, Hall & Casey, Washington, D. C., and Pierce, Atwood, Scribner, Allen & McKusick, Portland, Me., on brief, for American Life Convention and Life Ins. Assn. of America as amici curiae.
Before BRYAN and WINTER, Circuit Judges, and McMILLAN, District Judge.
United States Court of Appeals Fourth Circuit.
WINTER, Circuit Judge:
These appeals present myriad issues as to the application and interpretation of the Life Insurance Company Income Tax Act of 1959. 26 U.S.C.A. § 801 et seq.1 For the taxable years 1958 and 1959 Jefferson Standard Life Insurance Company ("taxpayer" and sometimes "Jefferson") filed consolidated returns with its wholly-owned subsidiary Pilot Life Insurance Company ("Pilot"). After assessment and payment of taxes...
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