MODERN SECURITY LIFE INSURANCE COMPANY v. COMMISSIONER

Docket No. 31186-84.

51 T.C.M. 188 (1985)

T.C. Memo. 1985-629

Modern Security Life Insurance Company, Successor in Interest to Dynamic Security Life Insurance Company v. Commissioner.

United States Tax Court.

Filed December 30, 1985.


Attorney(s) appearing for the Case

Raymond Turner, for the petitioner. Gary A. Benford, for the respondent.


Memorandum Opinion

DRENNEN, Judge:

This case was assigned to Special Trial Judge Daniel J. Dinan for the purpose of hearing the parties' cross motions for summary judgment, pursuant to the provisions of section 7456(c) and (d)1 and Delegation Order No. 8, 81 T.C. XXV (1983). After a review of the record, we agree with and adopt his opinion which is set forth below.

Opinion of the Special Trial Judge

DINAN, Special...

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