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CAL-FARM INS. CO. v. UNITED STATES

Civ. No. S-84-0157 MLS.

647 F.Supp. 1083 (1986)

CAL-FARM INSURANCE COMPANY, a California corporation, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, E.D. California.

September 5, 1986.

Attorney(s) appearing for the Case

Forrest A. Plant, William B. Shubb, William W. Sumner, Diepenbrock, Wulff, Plant & Hannegan, Thomas F. Olsen, Gen. Counsel (Cal-Farm), Sacramento, Cal., for plaintiff.

Yoshinori H.T. Himel, Asst. U.S. Atty., Sacramento, Cal., Scott A. Milburn, Trial Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

MEMORANDUM AND ORDER

MILTON L. SCHWARTZ, District Judge.

On November 16, 1984, plaintiff and defendant filed cross-motions for summary judgment. The court took the motions under submission and now renders its decision.

I. Factual Background

In 1975, plaintiff/taxpayer Cal-Farm Insurance Company claimed a deduction of $1,471,635 for a payment to its subsidiary Cal-Farm Life Insurance Company. The two companies were formed by the California...

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