Republic National Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-Appellee

This appeal was orally argued in Dallas, March 8, 1979.

This federal income tax case involves the complex provisions of the Internal Revenue Code relating to the taxation of life insurance companies.

There were three issues before the District Court, two of which involved deferred and uncollected premiums. Subsequent to the District Court decision, the United States Supreme Court decided Commissioner of Internal Revenue v. Standard Life & Accident Insurance Company, 433 U.S. 148, 97 S.Ct. 2523, 53 L.Ed.2d 653 (1977). It is clear, and the parties agree, that resolution of the two issues…