Western and Southern Life Insurance Company v. Commissioner of Internal Revenue

KENT, Circuit Judge.

This is an appeal from a decision of the Tax Court. 55 T.C. 1036. The appeal raises issues requiring the interpre tation and application of the Life Insurance Company Income Tax Act of 1959, Sections 801 et seq., Internal Revenue Code, 1954. 26 U.S.C. § 801 et seq. The Commissioner of Internal Revenue appeals from the decision of the Tax Court, which held that the appellee, Western and Southern Life Insurance Company (Insurance Company), in computing its taxable income under the Act, could offset the net valuation premiums on deferred and uncollected premiums and due and…