WESTERN AND SOUTHERN LIFE INSURANCE COMPANY, Petitioner-Appellee,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.
United States Court of Appeals, Sixth Circuit.https://leagle.com/images/logo.png
May 12, 1972.
May 12, 1972.
Attorney(s) appearing for the Case
Thomas L. Stapleton, Tax Div., Dept. of Justice, Washington, D. C., for appellant; Fred B. Ugast, Acting Asst. Atty. Gen., Meyer Rothwacks, Atty., Tax Div., Dept. of Justice, Washington, D. C., on brief.
Alan R. Vogeler, Cincinnati, Ohio, for appellee; Alan R. Vogeler, Cincinnati, Ohio, Arthur K. Mason, Washington, D. C., on brief; Kyte, Conlan, Wulsin & Vogeler, Cincinnati, Ohio, of counsel.
William B. Harman, Jr., Kenneth L. Kimble, William T. Gibb, Washington, D. C., on brief amici curiae of American Life Convention and Life Ins. Assn. of America.
Before CELEBREZZE and KENT, Circuit Judges, and KINNEARY, District Judge.
United States Court of Appeals, Sixth Circuit.
KENT, Circuit Judge.
This is an appeal from a decision of the Tax Court. 55 T.C. 1036. The appeal raises issues requiring the interpretation and application of the Life Insurance Company Income Tax Act of 1959, Sections 801 et seq., Internal Revenue Code, 1954. 26 U.S.C. § 801 et seq. The Commissioner of Internal Revenue appeals from the decision of the Tax Court, which held...
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