Legal Opinion
Cal-Farm Insurance v. United States
District Court, E.D. California
Decided September 5, 1986No. Civ. S-84-0157 MLSPublishedCited by 5 opinions
1Opinion of the Court
MEMORANDUM AND ORDER
MILTON L. SCHWARTZ, District Judge.
On November 16, 1984, plaintiff and defendant filed cross-motions for summary judgment. The court took the motions under submission and now renders its decision.
I. Factual Background
In 1975, plaintiff/taxpayer Cal-Farm Insurance Company claimed a deduction of $1,471,635 for a payment to its subsidiary Cal-Farm Life Insurance Company. The two companies were formed by the California Farm Bureau Federation, a non-profit organization, to provide insurance to its members at the lowest possible cost. The payment made in 1975 was for alleged…
2Cases cited37 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
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3Cited by5 opinions
- Duquesne Light Holdings Inc v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2017
- Pennzoil-quaker State Co. & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2004
- Cal-Farm Ins. Co. v. United StatesCourt of Appeals for the Ninth Circuit · 1987
- Duquesne Light Holdings Inc v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2017
- Kenneth Heiting v. United StatesCourt of Appeals for the Seventh Circuit · 2021