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ECONOMY FINANCE CORPORATION v. UNITED STATES

Nos. 72-2024, 72-2025.

501 F.2d 466 (1974)

ECONOMY FINANCE CORPORATION, Transferee of the Assets of National Public Life Insurance Company, and United Public Life Insurance Company, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided July 16, 1974.

Attorney(s) appearing for the Case

Scott P. Crampton, Asst. Atty. Gen., John A. Townsend, Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., Stanley B. Miller, U.S. Atty., Indianapolis, Ind., for defendant-appellant.

Theodore R. Dann, Indianapolis, Ind., William A. Cromartie, Chicago, Ill., for plaintiffs-appellees.

Before STEVENS and SPRECHER, Circuit Judges, and CAMPBELL, Senior District Judge.

SPRECHER, Circuit Judge.

These consolidated appeals involve the qualification of National Public Life Insurance Company1 and United Public Life Insurance Company (taxpayers) for tax treatment under 26 U.S.C. § 801 as life insurance companies.

I

During the taxable year of 1959, National Public Life Insurance Company (National Life), a wholly owned subsidiary of Economy Finance Corporation, was engaged in reinsurance...

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