February 24, 1994
SECURITIES AND EXCHANGE COMMISSION
450 Fifth Street, N. W.
Judiciary Plaza
Washington, D. C. 20549
RE: Rule 24f-2 Notice for Torchmark Insured Tax-Free Fund, Inc.
File Nos. 33-49071 and 811-7045/CIK#892250
Dear Sir or Madam:
1. This Notice is being filed for the fiscal period ended December 31, 1993;
2. At the beginning of such fiscal period the issuer had no securities
registered under the Securities Act of 1933, other than pursuant to this
section;
3. During such fiscal period the issuer registered no securities other than
pursuant to this section;
4. The issuer sold 206,433 shares during such fiscal period*; and
5. The 206,433 shares were sold during such fiscal period in reliance upon
registration pursuant to this section.
This Notice is accompanied by an opinion of counsel as prescribed by paragraph
(b)(1)(v) of Rule 24f-2. We have wired $712.09 in payment of the filing fee
prescribed by paragraph (c) of said Rule.
Very truly yours,
Sharon K. Pappas
Secretary
*During such fiscal period ended December 31, 1993, the issuer sold 206,433
shares in reliance upon registration pursuant to Rule 24f-2 at an actual
aggregate sale price of $2,065,047. No shares were redeemed. The filing fee,
calculated in the manner specified in Section 6(b) of the Securities Act of
1933, is based on the actual sale price of $2,065,047 for which shares were sold
during the issuer's previous fiscal period.
February 24, 1994
Torchmark Insured Tax-Free Fund, Inc.
6300 Lamar Avenue
P. O. Box 29217
Shawnee Mission, Kansas 66201-9217
Dear Sir or Madam:
In connection with the public offering of shares of Capital Stock, par value
$0.01 per share of Torchmark Insured Tax-Free Fund, Inc., I have examined such
corporate records and documents and have made such further investigation and
examination as I deemed necessary for the purpose of this opinion.
It is my opinion that the 206,433 shares of Capital Stock of Torchmark Insured
Tax-Free Fund, Inc., registration of which the notice makes definite in number,
were legally issued, fully paid and nonassessable.
I hereby consent to the filing of this opinion with the Rule 24f-2 Notice.
Very truly yours,
Rodney O. McWhinney
Attorney at Law
