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ALLSTATE INSURANCE COMPANY v. UNITED STATES

No. 410-65.

419 F.2d 409 (1969)

ALLSTATE INSURANCE COMPANY v. The UNITED STATES.

United States Court of Claims.

December 12, 1969.

Attorney(s) appearing for the Case

William A. Cromartie, Chicago, Ill., attorney of record, for plaintiff. Glen H. Kanwit, Chicago, Samuel H. Horne, Washington, D. C., and Hopkins, Sutter, Owen, Mulroy, Wentz & Davis, Chicago, Ill., of counsel.

Gilbert W. Rubloff, Washington, D. C., with whom was Asst. Atty. Gen., Johnnie M. Walters, for defendant. Philip R. Miller, Washington, D. C., of counsel.

Before COWEN, Chief Judge, LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON, and NICHOLS, Judges.

ON PLAINTIFF'S MOTION AND DEFENDANT'S CROSS MOTION FOR SUMMARY JUDGMENT

SKELTON, Judge.

This is an income tax case and is before the court on cross motions for summary judgment of the parties.

The plaintiff, Allstate Insurance Company, is an Illinois corporation with its principal office at Skokie, Illinois. It is a stock casualty insurance company. During the year 1958 it sold insurance policies in each of the provinces of the Dominion of Canada...

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