February 21, 1995
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, 1994;
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 4,202 shares during such fiscal period*; and
5. The 4,202 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 $8.51 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, 1994, the issuer sold 4,202 shares
in reliance upon registration pursuant to Rule 24f-2 at an actual aggregate sale
price of $42,096 and redeemed 1,832 shares at an aggregate repurchase price of
$17,408. None of such redeemed shares were previously applied by the issuer
pursuant to Section 24e-2(a) in filings made pursuant to Section 24(e)(1) of the
Investment Company Act of 1940. The filing fee, calculated in the manner
specified in Section 6(b) of the Securities Act of 1933, is based on the actual
sales price of $42,096 for which shares were sold during the issuer's previous
fiscal period reduced by the actual redemption price of $17,408 for which shares
were redeemed by the issuer during such previous fiscal period.
February 21, 1995
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 4,202 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,
Sharon K. Pappas
Attorney at Law
SKP:ss
