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FIRST SECURITY BANK v. UNITED STATES

Civ. No. 2149.

213 F.Supp. 362 (1963)

FIRST SECURITY BANK, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court D. Montana, Havre-Glasgow Division.

January 22, 1963.

Attorney(s) appearing for the Case

Thomas Dignan, Glasgow, Mont., and Hugh D. Galusha, Jr., Peter Meloy, and Robert C. Johnson, Helena, Mont., for plaintiff.

Louis F. Oberdorfer, Asst. Atty. Gen., Edward S. Smith, Fred J. Neuland, and Burton A. Schwalb, Dept. of Justice, Washington, D. C., and Moody Brickett, U. S. Atty., Butte, Mont.

JAMESON, District Judge.

Plaintiff seeks recovery of deficiencies in income taxes for the years 1952 to 1955, inclusive. Plaintiff is a bank incorporated under the laws of Montana. During the taxable years in question it operated at Glasgow, Montana, under the name of Farmers-Stockgrowers Bank. Its name was changed to its present form in 1957.

The primary questions presented are (1) whether plaintiff's stockholders created a partnership which operated an insurance...

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