New York Life Insurance Company v. United States

118 F.3d 1553

80 A.F.T.R.2d 97-5117, 97-2 USTC P 50,569

NEW YORK LIFE INSURANCE COMPANY, Plaintiff-Appellee,

v.

The UNITED STATES, Defendant-Appellant.

No. 96-5052.

United States Court of Appeals,

Federal Circuit.

July 3, 1997.

Rehearing Denied; Suggestion for Rehearing In Banc Declined

Sept. 26, 1997.*

Arthur L. Bailey, Steptoe & Johnson, Washington, DC, argued, for plaintiff-appellee. With him on the brief was J. Walker Johnson. Of counsel on the brief were Gerald Kaplan and Michael Oleske, New York Life Insurance Company, New York City.

Gilbert S. Rothenberg, Tax Division, Department of Justice,…