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NATIONAL CHIROPRACTIC INSURANCE CO. v. UNITED STATES

Civ. No. 72-164-1.

365 F.Supp. 971 (1973)

NATIONAL CHIROPRACTIC INSURANCE COMPANY, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, S. D. Iowa, C. D.

October 3, 1973.

Attorney(s) appearing for the Case

Kent M. Forney and Robert E. Drey (Bradshaw, Fowler, Proctor & Fairgrave), Des Moines, Iowa, for plaintiff.

Allen L. Donielson, U. S. Atty., Robert L. Fanter, First Asst. U. S. Atty., James R. Rosenbaum, Asst. U. S. Atty., Des Moines, Iowa, David A. Wilson, Jr. and Thomas R. Jones, Attys., Tax Div., Dept. of Justice and Scott P. Crampton, Asst. Atty. Gen., Washington, D. C., for defendant.

MEMORANDUM AND RULING

STUART, District Judge.

Taxpayer is a mutual insurance company incorporated under the laws of the State of Iowa, Chapter 515, Code of Iowa, 1973, having its principal place of business in Des Moines. During the years in question in this suit, 1965 through 1970, taxpayer had filed each year Form 1120M, mutual insurance company income tax forms. These forms were audited for the years in question, and deficiencies in tax and interest were...

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