Legal Opinion
American National Insurance v. United States
United States Court of Claims
Decided September 22, 1982No. Nos. 336-73 and 193-78PublishedCited by 16 opinions
1Opinion of the CourtFriedman, Chief Judge
The principal issue in this case, and the only one we discuss on the merits, is whether "experience rating refunds” that the plaintiff life insurance company was contractually obligated to pay to certain of its policyholders constituted "return premiums” or "dividends to policyholders” under the Life Insurance Company Income Tax Act of 1959, Pub. L. No. 86-69, 73 Stat. 112 (codified as amended at 26 U.S.C. §§801-20 (1976 & Supp. IV 1980) [hereinafter referred to as the "Code” and cited as I.R.C.]) (the "Life Insurance Tax Act”).
The significance of this distinction is that in determining a…
2Cases cited8 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- 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
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
- Lincoln National Life Insurance v. United StatesUnited States Court of Claims · 1978
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Applegate v. United StatesUnited States Court of Federal Claims · 1996
- Prairie States Life Insurance Co. v. United StatesCourt of Appeals for the Eighth Circuit · 1987
- Aetna Life Insurance v. United StatesUnited States Court of Claims · 1989
- North Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Modern American Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
11 more not listed; retrieve them via the Exa API.