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REPUBLIC NAT. LIFE INS. CO. v. UNITED STATES

No. 77-2062.

594 F.2d 530 (1979)

REPUBLIC NATIONAL LIFE INSURANCE COMPANY, Plaintiff-Appellee-Cross-Appellant, v. UNITED STATES of America, Defendant-Appellant-Cross-Appellee.

United States Court of Appeals, Fifth Circuit.

May 7, 1979.

Attorney(s) appearing for the Case

Kenneth J. Mighell, U. S. Atty., Fort Worth, Tex., Gilbert E. Andrews, Act. Chief, Appellate Section, U. S. Dept. of Justice, Washington, D. C., Martha Joe Stroud, Asst. U. S. Atty., Dallas, Tex., M. Carr Ferguson, Asst. Atty. Gen., Gary R. Allen, Robert A. Bernstein, Atty., Dept. of Justice, Tax Div., Washington, D. C., for defendant-appellant-cross-appellee.

Larry L. Bean, H. Martin Gibson, Vester T. Hughes, Jr., W. John Glancy, Dallas, Tex., for plaintiff-appellee-cross-appellant.

Before COLEMAN, GODBOLD, and INGRAHAM, Circuit Judges.

PER CURIAM:

This appeal was orally argued in Dallas, March 8, 1979.

This federal income tax case involves the complex provisions of the Internal Revenue Code relating to the taxation of life insurance companies.

There were three issues before the District Court, two of which involved deferred and uncollected premiums. Subsequent to the District Court decision, the United States Supreme Court decided Commissioner of Internal Revenue v. Standard Life...

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