Liberty Life Insurance v. United States
District Court, D. South Carolina
1Opinion of the Court
FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER
CHAPMAN, District Judge.
This action was instituted by the plaintiff Liberty Life Insurance Company pursuant to 28 U.S.C. § 1346(a), seeking to recover income taxes in the amount of $87,660.71 for the year 1965, including interest, alleged to have been erroneously collected from it by the defendant.
The dispute arises from the adoption by Liberty Life of a novel accounting method whereby certain items are considered to be investment expenses within the meaning of 26 U.S.C. § 804(c)(1). The United States asserts by way of set-off, a claim for taxes…
2Cases cited8 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Missouri Pacific Railroad Company v. The United StatesUnited States Court of Claims · 1964
- Jefferson Standard Life Insurance Company v. United States of America, (Two Cases). Jefferson Standard Life Insurance Company v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1969
- Helvering v. Illinois Life InsuranceSupreme Court of the United States · 1936
- Commissioner of Internal Rev. v. Monarch Life Ins. Co.Court of Appeals for the First Circuit · 1940
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3Cited by1 opinion
- In re Estate of WelshCommonwealth Court of Pennsylvania · 1986