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STANDARD LIFE & ACC. INS. CO. v. C. I. R.

No. 75-1075.

525 F.2d 786 (1975)

STANDARD LIFE & ACCIDENT INSURANCE COMPANY, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Tenth Circuit.

Rehearing Denied January 8, 1976.

Attorney(s) appearing for the Case

Gene A. Castleberry, Oklahoma City, Okl., for appellant.

Meade Whitaker and Gary R. Allen, Attys., Tax Div., Dept. of Justice, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Washington, D. C., Gilbert E. Andrews and Bennet N. Hollander, Attys., Tax Div., Dept. of Justice, Washington, D. C., on the brief), for appellee.

Before HOLLOWAY, McWILLIAMS and BARRETT, Circuit Judges.

BARRETT, Circuit Judge.

Standard Life & Accident Insurance Company (taxpayer) appeals a Tax Court decision1 which upheld the Commissioner's deficiency determination against taxpayer for the years 1958, 1959 and 1961. A recitation of the pertinent facts, which were fully stipulated to, will facilitate our review.

Taxpayer, an Oklahoma corporation, is a life insurance company as defined by the Internal Revenue Code, 26 U.S.C...

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