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LIBERTY LIFE INS. CO. v. UNITED STATES

Civ. A. No. 73-1538.

439 F.Supp. 927 (1977)

LIBERTY LIFE INSURANCE COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. South Carolina, Greenville Division.

August 20, 1977.

Attorney(s) appearing for the Case

David A. Merline, Greenville, S.C., for plaintiff.

J. D. McCoy, III, Asst. U.S. Atty., Greenville, S.C., Hubert M. Doster, Fred Luyties, James E. Crowe, Jr., Tax Div., Dept. of Justice, Washington, D.C., for defendant.

FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER

CHAPMAN, District Judge.

This action was instituted by the plaintiff Liberty Life Insurance Company pursuant to 28 U.S.C. § 1346(a), seeking to recover income taxes in the amount of $87,660.71 for the year 1965, including interest, alleged to have been erroneously collected from it by the defendant.

The dispute arises from the adoption by Liberty Life of a novel accounting method whereby certain...

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