Group Life and Health Insurance Company v. The United States of America

RANDALL, Circuit Judge:

Defendant-Appellant, the United States of America (“United States”), brings this appeal from an adverse judgment in the court below in a suit brought against it by Group Life and Health Insurance Company (“Group Life”). Group Life, the taxpayer in this case, successfully challenged a ruling by the Internal Revenue Service (“the Service”) that it did not qualify for advantageous tax treatment as a life insurance company under the Internal Revenue Code (“the Code”) and was awarded a refund of $614,270.89 in taxes it had paid for the tax year 1967. We find that the trial…