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CREDIT UNION INS. CORP. v. U.S.

No. 95-2267.

86 F.3d 1326 (1996)

CREDIT UNION INSURANCE CORPORATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fourth Circuit.

Decided June 18, 1996.

Attorney(s) appearing for the Case

ARGUED: Kenneth Larry Greene, Tax Division, United States Department of Justice, Washington, DC, for Appellant. Roger D. Redden, Piper & Marbury, L.L.P., Baltimore, Maryland, for Appellee. ON BRIEF: Loretta C. Argrett, Assistant Attorney General, Gary R. Allen, Curtis C. Pett, Lynne Ann Battaglia, United States Attorney, Tax Division, United States Department of Justice, Washington, DC, for Appellant. Joseph H. Langhirt, Martin E. Wolf, Piper & Marbury, L.L.P., Baltimore, MD, for Appellee.

Before RUSSELL and ERVIN, Circuit Judges, and NORTON, United States District Judge for the District of South Carolina, sitting by designation.

Affirmed by published opinion. Judge RUSSELL wrote the opinion, in which Judge ERVIN and Judge NORTON joined.

OPINION

DONALD S. RUSSELL, Circuit Judge:

In this case, we must determine whether Credit Union Insurance Corporation ("CUIC") is entitled to exemption from federal income tax.

CUIC was chartered in 1974 by an act of the Maryland General Assembly as a nonprofit, non-stock corporation, the members of which are credit unions that apply...

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