Legal Opinion
Liberty National Life Insurance Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-Cross (Two Cases)
Court of Appeals for the Fifth Circuit
Decided July 12, 1972No. 71-2776PublishedCited by 18 opinions
1Opinion of the Court
RIVES, Circuit Judge:
We are here asked to tread through the difficult maze of the federal income tax laws which govern life insurance companies. The Government assessed taxpayer, Liberty National Life Insurance Company (“Liberty”), with a deficiency of $80,389.99 for the tax years in question, 1964 and 1965. Liberty filed this suit in federal district court seeking a refund. The issue distills into whether certain escrow mortgage funds are “assets” within the meaning of section 805(b)(4) of the Internal Revenue Code of 1954. Some of the funds in question were commingled by Liberty in its…
2Cases cited7 opinions
- National Bank v. Insurance Co.Supreme Court of the United States · 1881
- 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
- Western National Life Insurance Company of Texas v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Western Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1968
- Western Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1969
2 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Eugene Telfair v. First Union Mortgage CorporationCourt of Appeals for the First Circuit · 2000
- Southwestern Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Stavrides v. Mellon National Bank & Trust CompanyDistrict Court, W.D. Pennsylvania · 1973
- Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
- Alexander Stavrides v. Mellon National Bank & Trust CompanyCourt of Appeals for the Third Circuit · 1973
13 more not listed; retrieve them via the Exa API.