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NORTH AMERICAN LIFE & CAS. CO. v. C. I. R.

No. 75-1380.

533 F.2d 1046 (1976)

NORTH AMERICAN LIFE AND CASUALTY CO., Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Appellant.

United States Court of Appeals, Eighth Circuit.

Decided April 14, 1976.

Attorney(s) appearing for the Case

Arthur L. Bailey, Atty., Tax Div., Dept. of Justice, Washington, D. C., for appellant; Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, and Gary R. Allen, Attys., Tax Div., Dept. of Justice, Washington, D. C., on briefs.

Michael J. Cuddy, New York City, for appellee.

Before GIBSON, Chief Judge, CLARK, Associate Justice, Retired, and BRIGHT, Circuit Judge.

GIBSON, Chief Judge.

This is an appeal from a decision of the United States Tax Court1 overturning the Commissioner of Internal Revenue's disallowance of deductions taken by the taxpayer, North American Life and Casualty Co., for commission expenses attributable to premiums deferred and uncollected during the tax years 1961 and 1963. Taxpayer, a stock plan life, accident and health insurance...

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