STEPHENSON, Circuit Judge.
The sole issue on this appeal is whether the district court correctly determined that the taxpayer-appellant did not qualify as a mutual insurance company for federal income tax purposes under § 821 of the Internal Revenue Code of 1954 (26 U.S.C. § 821) because of its requirement that policy holders waive their right to dividends and because of its failure to provide insurance at cost. The district court's decision is published...
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