Legal Opinion
Security Industrial Insurance Company v. United States
Court of Appeals for the Fifth Circuit
Decided April 22, 1983No. 81-3804, 81-3805PublishedCited by 44 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
This appeal of a tax refund suit concerns the taxability of certain policyholders surplus accounts, 1 which assertedly were carried over tax-free from Southern National Life Insurance Co. (“Southern”) and Standard Life Insurance Co. (“Standard”) to appellee Security Industrial Insurance Co. (“Security”). The district court found that reorganizations described in section 368(a)(1)(F) (“F reorganizations”) had occurred and permitted the carryover of the policyholders surplus accounts. Because we believe that the district court erred in failing to apply the step…
2Cases cited24 opinions
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Commissioner v. GordonSupreme Court of the United States · 1968
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
- American Bantam Car Co. v. CommissionerUnited States Tax Court · 1948
19 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- Leonard Greene and Joyce Greene v. United StatesCourt of Appeals for the Second Circuit · 1994
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Penrod v. CommissionerUnited States Tax Court · 1987
- TRUE v. United StatesCourt of Appeals for the Tenth Circuit · 1999
- Trinity Marine Products, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2016
39 more not listed; retrieve them via the Exa API.