Drummond Citizens Insurance Company, Formerly Citizens Burial Insurance Company, a Corporation v. United States

The District Court for the Eastern District of Arkansas granted the government’s motion for summary judgment holding that the taxpayer was not a life insurance company within the meaning of Int.Rev.Code of 1954, § 801, and that the taxpayer therefore, could not receive the favorable tax treatment accorded life insurance companies thereunder.

The taxpayer appealed from that decision arguing that it was a qualified insurance company based upon the alternate grounds: (1) that it issued and had outstanding only life insurance policies and that the qualification formula o.f § 801, therefore, was…