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C. I. R. v. PACIFIC MUTUAL LIFE INSURANCE COMPANY

No. 22580.

413 F.2d 55 (1969)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. PACIFIC MUTUAL LIFE INSURANCE COMPANY, Respondent.

United States Court of Appeals Ninth Circuit.

June 11, 1969.

Attorney(s) appearing for the Case

Gilbert E. Andrews, Jr., Washington, D. C. (argued), Mitchell Rogovin, Asst. Atty. Gen., Meyer Rothwacks, Thomas L. Stapleton, Attys., Dept. of Justice, Lester Uretz, Chief Counsel, I. R. S., Washington, D. C., for petitioner.

Richard N. Mackay (argued), A. Calder Mackay, of Mackay, McGregor & Bennion, Los Angeles, Cal., for respondent.

Before JERTBERG, BROWNING and DUNIWAY, Circuit Judges.

JERTBERG, Circuit Judge:

Before us is a petition by the Commissioner of Internal Revenue to review a decision of the Tax Court of the United States1 involving income taxes for the years 1958 through 1961, holding that the guaranteed renewable accident and health insurance contracts issued by the taxpayer, Pacific Mutual Life Insurance Company, were "issued or renewed for periods of five years or more" within the purview of Sec. 809(d)...

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