Rehearing Denied and Rehearing En Banc Denied January 8, 1971.
ADAMS, Circuit Judge:
This case presents an important and difficult question concerning the Federal taxation of guaranteed renewable health and accident insurance companies under Subchapter L, Part I, § 801 et seq. of the Internal Revenue Code of 1954.
Plaintiff Group Life and Health Insurance Company ("Group Life") underwrites and issues group insurance in Texas under the plan known...
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