Legal Opinion
The Dow Chemical Company v. United States
Court of Appeals for the Sixth Circuit
Decided January 23, 2006No. 03-2360PublishedCited by 40 opinions
1Opinion of the Court
OPINION
MOORE, Circuit Judge.
In 1988 and 1991, Plaintiff-Appellee The Dow Chemical Company (“Dow”) purchased corporate-owned life insurance (“COLI”) policies on the lives of thousands of its employees. In the taxable years 1989 to 1991, Dow claimed deductions for interest incurred on loans used to pay the COLI premiums- and for fees related to the administration of the policies. The Internal Revenue Service (“IRS”) disallowed these deductions and assessed tax deficiencies and interest, which Dow paid under protest and attempted to recover by suing for a refund. Following a bench trial, the…
2Cases cited23 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
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3Cited by40 opinions
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- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
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