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LIBERTY NAT. LIFE INS. CO. v. UNITED STATES

No. 77-1578.

600 F.2d 1106 (1979)

LIBERTY NATIONAL LIFE INSURANCE COMPANY, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied September 20, 1979.

Attorney(s) appearing for the Case

Gilbert E. Andrews, Act. Chief, App. Section, M. Carr Ferguson, Asst. Atty. Gen., Gary R. Allen, James E. Crowe, Attys., U.S. Dept. of Justice, Washington, D.C., Tax Div., for defendant-appellant.

Ralph B. Tate, Ira L. Burleson, Theron A. Guthrie, Jr., Birmingham, Ala., for plaintiff-appellee.

Before THORNBERRY, GOLDBERG and GEE, Circuit Judges.

THORNBERRY, Circuit Judge:

Once again1 we are asked to enter the "fantasy world of life insurance company accounting and taxation." Western Nat'l Life Ins. Co. v. Commissioner, 51 T.C. 824, 830 (1969). The issue we must decide is whether discounts taxpayer Liberty National Life Insurance Company gave to holders of its industrial life insurance policies who paid at least twenty-six weeks of premiums...

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