Legal Opinion
Clougherty Packing Company v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided March 3, 1987No. 85-7707PublishedCited by 60 opinions
1Opinion of the Court
REINHARDT, Circuit Judge:
We are presented with another version of a not so novel question: Are amounts paid as “insurance premiums” by a parent corporation to its “captive insurance company” 1 subsidiary deductible for purposes of federal income taxation? This latest twist, like the previous case we considered, Carnation Co. v. Commissioner, 640 F.2d 1010 (9th Cir.), cert. denied, 454 U.S. 965, 102 S.Ct. 506, 70 L.Ed.2d 381 (1981), aff'g 71 T.C. 400 (1978), involves the purchase by a parent of insurance from an unrelated insurance company and the reinsurance by the unrelated company of the…
2Cases cited21 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Helvering v. Le GierseSupreme Court of the United States · 1941
- National Investors Corporation v. HoeyCourt of Appeals for the Second Circuit · 1944
16 more not listed; retrieve them via the Exa API.
3Cited by60 opinions
- EXECUTIVE RISK INDEMNITY, INC. v. Charleston Area Medical Center, Inc.District Court, S.D. West Virginia · 2009
- Northern Indiana Public Service Company v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1997
- 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
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
55 more not listed; retrieve them via the Exa API.