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WORLD SERVICE LIFE INSURANCE COMPANY v. UNITED STATES

No. 72-1169.

471 F.2d 247 (1973)

WORLD SERVICE LIFE INSURANCE COMPANY, as Corporate Successor to Stockman National Life Insurance Company, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eighth Circuit.

Decided January 8, 1973.

Attorney(s) appearing for the Case

Richard W. Halberstein, Asst. U. S. Atty., Sioux Falls, S. D., for appellant.

George A. Bangs, Bangs, McCullen, Butler, Foye & Simmons, Rapid City, S. D., for appellee.

Before LARAMORE, United States Court of Claims Senior Judge, and BRIGHT and ROSS, Circuit Judges.

LARAMORE, Senior Judge.

We are called upon in this case to review the question of whether the corporate taxpayer herein was entitled to certain net operating loss carryovers from a corporation which it acquired in a "taxfree" reorganization pursuant to section 368(a)(1)(C).1 Resolution of this question ultimately devolves to the validity of Treasury Regulation § 1.-382(b)-1(a)(2).

Plaintiff-Appellee, World Service Life Insurance...

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