Drummond Citizens Insurance v. United States

Memorandum Opinion

HENLEY, Chief Judge.

This tax refund suit, which is now before the Court on the cross motions of the parties for summary judgment, involves the 1962 federal income tax liability of Citizens Burial Insurance Co. of West Memphis, Arkansas, hereinafter Citizens, which during the tax year in question, and during prior and subsequent years, was an Arkansas life insurance company chartered as a “stipulated premium” insurer under the provisions of Act 137 of 1925, Pope’s 1937 Digest of the Statutes of Arkansas, § 7820 et seq.

In 1965 the controlling stock in Citizens was acquired by…