Legal Opinion
National Life Insurance Company and Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 20, 1996No. 1446, Docket 95-4025PublishedCited by 9 opinions
1Opinion of the Court
WALKER, Circuit Judge:
National Life Insurance Company and its subsidiaries (collectively “National Life”) ap peal from a decision of the Tax Court (Mary Ann Cohen, Judge), denying National Life’s petition to increase its deduction from its gross income for policyholder dividends for 1984 by $40,762,000, pursuant to § 808(c)(1) of the Internal Revenue Code, 26 U.S.C. § 808(c)(1). National Life Ins. Co. v. Commissioner, 103 T.C. 35, 103 T.C. No. 615, 1994 WL 696244 (1994). In 1984, Congress required that life insurance companies switch from the “reserve method” of accounting to the “accrual…
2Cases cited9 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Red Lion Broadcasting Co. v. Federal Communications CommissionSupreme Court of the United States · 1969
- E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
- Paul F. Belloff v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
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3Cited by9 opinions
- Danny Tuttle v. Equifax CheckCourt of Appeals for the Second Circuit · 1999
- John Maier, III v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2004
- Huffman v. CommissionerCourt of Appeals for the Sixth Circuit · 2008
- James M. Rankin Shirley Rankin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- New York Life Insurance v. United StatesCourt of Appeals for the Second Circuit · 2013
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