BLACKFEET NAT. BANK v. RUBIN

Civ. A. No. 95-0979.

890 F.Supp. 48 (1995)

BLACKFEET NATIONAL BANK, et al., Plaintiffs, v. Robert E. RUBIN, Secretary of the Treasury, Defendant.

United States District Court, District of Columbia.

June 29, 1995.


Attorney(s) appearing for the Case

Dennis M. Gingold and Thaddeus Holt, Washington, DC, for plaintiffs.

Stuart D. Gibson, U.S. Dept. of Justice, Washington, DC, for defendant.


OPINION AND ORDER

FRIEDMAN, District Judge.

BACKGROUND

American Deposit Corporation ("ADC") developed an innovative financial instrument, which it named the Retirement CD, to exploit a tax code provision permitting companies other than insurance companies to issue tax-deferred annuities. See 26 U.S.C. § 1275(a)(1)(B). The Retirement CD has many of the characteristics of an ordinary certificate of deposit. By combining the CD...

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