Legal Opinion
Gulf Life Insurance Company v. United States
Court of Appeals for the Federal Circuit
Decided July 8, 1997No. 96-5138PublishedCited by 8 opinions
1Opinion of the Court
PAULINE NEWMAN, Circuit Judge.
This case concerns the placement of tax liability in connection with “participating” life insurance policies upon which indemnity reinsurance has been obtained. The policyholder receives premium rebates, called dividends, which vary with the insurer’s interest earnings and thus provide the insurer with flexibility to accommodate varying investment proceeds. For the tax year 1977 the insurer, Gulf Life Insurance Company’s predecessor company Life & Casualty Insurance Company of Tennessee (Taxpayer), obtained indemnity reinsurance of these rebates. The issue is…
2Cases cited7 opinions
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- O'Gilvie v. United StatesSupreme Court of the United States · 1996
- United States v. Consumer Life Insurance Co.Supreme Court of the United States · 1977
- Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
- Colonial American Life Insurance v. CommissionerSupreme Court of the United States · 1989
2 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Tuttle v. New Hampshire Medical Malpractice Joint Underwriting Ass'nSupreme Court of New Hampshire · 2010
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- Tuttle v. MED. MAL. JOINT UNDERWRITINGSupreme Court of New Hampshire · 2010
- Massachusetts Mutual Life Insurance v. United StatesUnited States Court of Federal Claims · 2012
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
3 more not listed; retrieve them via the Exa API.