BANK OF COUSHATTA v. UNITED STATES

No. 80-3152.

650 F.2d 75 (1981)

BANK OF COUSHATTA, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit. Unit A

July 6, 1981.


Attorney(s) appearing for the Case

M. Carr Ferguson, Asst. Atty. Gen., Michael L. Paup, Gilbert E. Andrews, Chief App. Sec., Gary R. Allen, Gilbert S. Rothenberg, Tax Div., Dept. of Justice, Washington, D. C., for defendant-appellant.

William H. Jeffress, Jr., Jamie S. Gorelick, Washington, D. C., Sidney E. Cook, Shreveport, La., Leon Gary, Jr., Baton Rouge, La., for amicus curiae (American Bank & Trust Co., et al.).

Blanchard, Walker, O'Quin & Roberts, J. Edgerton Pierson, Jr., Shreveport, La., for plaintiff-appellee.

Before GOLDBERG, CHARLES CLARK and REAVLEY, Circuit Judges.


GOLDBERG, Circuit Judge:

We affirm the decision of the district court on the basis of its Memorandum Ruling of February 21, 1980, a copy of which is reprinted below. In so doing, we feel it necessary to note that we read the district court's ruling as being limited to the situation in which the bank's decision to transfer the operation of the insurance business to individual agents was motivated by a good faith belief that...

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