Prairie States Life Insurance Co. v. United States
Court of Appeals for the Eighth Circuit
1Opinion of the Court
BOWMAN, Circuit Judge.
Prairie States Life Insurance Company (taxpayer) is a stock life insurance company. Following an audit of taxpayer’s returns for the years 1975 through 1978, the Internal Revenue Service assessed a deficiency. Taxpayer paid the assessed deficiency, and filed this suit for a refund and interest in District Court. The District Court, on cross-motions for summary judgment, ruled in favor of taxpayer on its claims that (1) certain distributions by taxpayer to its policyholders constituted “return premiums” under I.R.C. § 809(c)(1), 1 and that (2) with respect to a certain…
2Cases cited15 opinions
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