Legal Opinion
The Travelers Insurance Company v. United States
Court of Appeals for the Federal Circuit
Decided September 16, 2002No. 01-5137PublishedCited by 9 opinions
1Opinion of the Court
DYK, Circuit Judge.
This federal income tax refund case has been pending in the Court of Federal Claims for over a decade. It presents two issues, each of which relates to special rules for the taxation of life insurance companies, such as the Travelers Insurance Co. (“Travelers” or “taxpayer”), the appel-lee in this case. The first issue is whether the policyholders’ share of income should have been excluded from “taxable income” for purposes of computing the limitation on the foreign tax credit in section 904 of the Internal Revenue Code, 26 U.S.C. § 904 (1976). For life insurance companies,…
2Cases cited18 opinions
- Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Dickman v. CommissionerSupreme Court of the United States · 1984
13 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- JPMorgan Chase & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Wells Fargo & Co. v. Comm'rUnited States Tax Court · 2003
- The Travelers Insurance Company v. United StatesCourt of Appeals for the Federal Circuit · 2003
- Travelers Insurance v. United StatesUnited States Court of Federal Claims · 2006
- Jpmorgan Chase & Co. v. Commissioner Of Internal RevenueCourt of Appeals for the First Circuit · 2006
4 more not listed; retrieve them via the Exa API.