Legal Opinion
Carnation Company v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 13, 1981No. 79-7218PublishedCited by 63 opinions
1Opinion of the Court
WRIGHT, Circuit Judge:
Carnation appeals the Tax Court’s determination that its agreement with American Home Assurance Company (American Home) to the extent reinsured with a Carnation subsidiary was not “insurance” for tax purposes, and that payments made thereunder were not deductible as a business expense. We affirm.
I. FACTS
In August 1971, Carnation incorporated Three Flowers Assurance Co., Ltd. (Three Flowers) as its wholly owned Bermuda subsidiary. It created Three Flowers to insure and reinsure various multiple line risks, including its own and those of its subsidiaries. Three Flowers…
2Cases cited7 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Carnation Co. v. CommissionerUnited States Tax Court · 1978
- Spring Canyon Coal Co. v. Commissioner of Int. Rev.Court of Appeals for the Tenth Circuit · 1930
- Steere Tank Lines, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1978
2 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Clougherty Packing Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Vukasovich, Inc. v. Commissioner of Internal Revenue, Vukasovich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Humana Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Clougherty Packing Co. v. CommissionerUnited States Tax Court · 1985
58 more not listed; retrieve them via the Exa API.