Legal Opinion

Prairie States Life Insurance Co. v. United States

Court of Appeals for the Eighth Circuit

Decided July 17, 1987No. 86-5082PublishedCited by 16 opinions

1Opinion of the Court

BOWMAN, Circuit Judge.

Prairie States Life Insurance Company (taxpayer) is a stock life insurance company. Following an audit of taxpayer’s returns for the years 1975 through 1978, the Internal Revenue Service assessed a deficiency. Taxpayer paid the assessed deficiency, and filed this suit for a refund and interest in District Court. The District Court, on cross-motions for summary judgment, ruled in favor of taxpayer on its claims that (1) certain distributions by taxpayer to its policyholders constituted “return premiums” under I.R.C. § 809(c)(1), 1 and that (2) with respect to a certain…

2Cases cited15 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. United States v. DavisSupreme Court of the United States · 1962
  3. Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
  4. Commissioner v. TuftsSupreme Court of the United States · 1983
  5. Beneficial Life Ins. Co. v. CommissionerUnited States Tax Court · 1982

10 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. Colonial American Life Insurance v. CommissionerSupreme Court of the United States · 1989
  2. Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
  3. Tuttle v. New Hampshire Medical Malpractice Joint Underwriting Ass'nSupreme Court of New Hampshire · 2010
  4. North Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
  5. Merit Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988

11 more not listed; retrieve them via the Exa API.

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