GROUP LIFE & HEALTH INSURANCE CO. v. UNITED STATES

No. 28992.

434 F.2d 115 (1970)

GROUP LIFE & HEALTH INSURANCE COMPANY, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied and Rehearing Denied January 8, 1971.


Attorney(s) appearing for the Case

Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, Atty., Tax Div., Dept. of Justice, Washington, D. C., Jerry B. Wells, Tax. Div., Dept. of Justice, Eldon B. Mahon, U. S. Atty., Fort Worth, Tex., William L. Goldman, Atty., Dept. of Justice, Tax Div., Washington, D. C., for defendant-appellant.

O. Jan Tyler, Robert K. Sands, Wright Matthews, Dallas, Tex., for plaintiff-appellee.

Before GEWIN, MORGAN and ADAMS, Circuit Judges.


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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