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MUTUAL BENEFIT LIFE INSURANCE COMPANY v. C. I. R.

No. 73-1169.

488 F.2d 1101 (1974)

The MUTUAL BENEFIT LIFE INSURANCE COMPANY, (James P. Moore, Jr., Vice President and Comptroller), Appellee, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Decided December 12, 1973.

As Amended January 8, 1974.

Attorney(s) appearing for the Case

Henry W. Connelly, Shearman & Sterling, New York City, for appellee; Charles W. Kappes, Senior Vice President and Gen. Counsel, Newark, N. J., Michael J. Walsh, Shearman & Sterling, New York City, of counsel.

Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Ernest J. Brown, Acting Chief, App. Section, Tax Div., Dept. of Justice, Washington, D. C., for appellant.

Before SEITZ, Chief Judge and HUNTER and WEIS, Circuit Judges.

OPINION OF THE COURT

WEIS, Circuit Judge.

While there are many who complain that the Internal Revenue Code is incomprehensible, there are some few who revel in the intricacies of its labyrinthine composition. But those who take delight in such pursuits and who also understand the mystic processes of establishing reserves in the life insurance industry are an even rarer specie of the ornithological world. Such are...

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