Legal Opinion
Allstate Insurance Company v. The United States
Court of Appeals for the Federal Circuit
Decided June 19, 1991No. 90-5114PublishedCited by 10 opinions
1Opinion of the Court
RADER, Circuit Judge.
Allstate Insurance Company (Allstate) appeals from the final decision of the United States Claims Court denying its claim for a tax refund. The Claims Court held that the tax benefit rule did not apply to Allstate’s subrogation recoveries. Allstate Ins. Co. v. United States, 20 Cl.Ct. 308 (1990). This court reverses and remands.
BACKGROUND
Allstate is a property and casualty insurance company subject to taxation under sections 831 and 832 of the Internal Revenue Code. 26 U.S.C. §§ 831, 832 (1954). 1 Section 832 includes underwriting income within insurance company gross…
2Cases cited8 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Mingus Constructors, Inc. v. The United StatesCourt of Appeals for the Federal Circuit · 1987
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Bituminous Casualty Corp. v. CommissionerUnited States Tax Court · 1971
3 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Phillip Duncan Bronson v. United StatesCourt of Appeals for the Federal Circuit · 1995
- Berkley v. GavinSupreme Court of Connecticut · 2000
- Pine Products Corporation, Timber Investors, Inc. And Joint Venture v. The United StatesCourt of Appeals for the Federal Circuit · 1991
- American Mutual Life Insurance Company and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2001
- John Hancock Financial Services, Inc., and John Hancock Life Insurance Company (Formerly John Hancock Mutual Life Insurance Company) v. United StatesCourt of Appeals for the Federal Circuit · 2004
5 more not listed; retrieve them via the Exa API.