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GE LIFE AND ANNUITY CO. v. U.S.

No. CIV. A. 3:00CV148.

127 F.Supp.2d 794 (2000)

GE LIFE AND ANNUITY CO. (Formerly the Life Insurance Company of Virginia) Plaintiff, v. UNITED STATES of America Defendant.

United States District Court, E.D. Virginia. Richmond Division.

December 13, 2000.

Attorney(s) appearing for the Case

Douglas Michael Palais, McCandlish & Kaine, Richmond, VA, Dana Johannes Finberg, McCandlish Kaine, Richmond, VA, Richard Bromley, Hopkins & Sutter, Chicago, IL, for GE Life and Annuity Assur. Co.

G. Wingate Grant, U.S. Attorney's Office, Richmond, VA, Stuart D. Gibson, U.S. Dept. of Justice, Washington, DC, Joan E. Evans, U.S. Attorney's Office, Richmond, VA, for U.S.

MEMORANDUM

SPENCER, District Judge.

This matter is before the Court on the Parties' cross-motions for partial summary judgment. The issue presented is whether the Plaintiff's Policyholders Surplus Account was taxable in the short taxable year ended April 29, 1986.

FACTS

The Plaintiff, GE Life and Annuity Assurance Company is a stock life insurance company domiciled in and...

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