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INTERNATIONAL LIFE INSURANCE CO. v. C. I. R.

No. 19848.

427 F.2d 137 (1970)

INTERNATIONAL LIFE INSURANCE CO., (Formerly State Insurance Co. of Kentucky), Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Sixth Circuit.

June 2, 1970.

Attorney(s) appearing for the Case

William A. Cromartie, Chicago, Ill., Patrick A. Heffernan, William E. Barrows, Chicago, Ill., on the brief; Samuel H. Horne, Hopkins, Sutter, Owen, Mulroy, Wentz & Davis, Chicago, Ill., of counsel, for appellant.

Stanley L. Ruby, Dept. of Justice, Washington, D. C., Johnnie M. Walters, Asst. Atty. Gen., William A. Friedlander, William L. Goldman, Dept. of Justice, Washington, D. C., on the brief, for appellee.

Before PHILLIPS, Chief Judge, and EDWARDS and BROOKS, Circuit Judges.

PER CURIAM.

The taxpayer appeals from the decision of the Tax Court reported at 51 T.C. 765. The taxpayer is an insurance company organized under the laws of Kentucky. On March 22, 1966, its name was changed from State Insurance Company of Kentucky to International Life Insurance Company.

Another Kentucky insurance corporation, Republic Casualty Insurance Co. (Republic), was engaged in the business of issuing health and accident...

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