HANOVER INS. CO. v. U.S.

No. 89-1101.

880 F.2d 1503 (1989)

HANOVER INSURANCE COMPANY, Plaintiff, Appellant, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided August 7, 1989.

As Amended September 18, 1989.


Attorney(s) appearing for the Case

Harry T. Daniels with whom Betsy Hecker, William H. Paine and Hale and Dorr, Boston, Mass., were on brief, for plaintiff, appellant.

Charles Bricken, Tax Div., Dept. of Justice, with whom James I.K. Knapp, Acting Asst. Atty. Gen., Peter A. Mullin, Acting U.S. Atty., Gary R. Allen and Gilbert S. Rothenberg, Tax Div., Dept. of Justice, Washington, D.C., were on brief, for U.S.

Before CAMPBELL, Chief Judge, TORRUELLA and SELYA, Circuit Judges.


SELYA, Circuit Judge.

Judge Learned Hand once wrote that words can be "chameleons, which reflect the color of their environment...." Commissioner v. National Carbide Corp., 167 F.2d 304, 306 (2d Cir.1948). That was hardly news to generations of lawyers and judges, many of whom have learned, often at some cost, that the same language, used in different settings, may mean very different things. While the mechanical provisions...

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