Legal Opinion
Superior Life Insurance Company v. United States of America, Superior Life Insurance Company v. United States
Court of Appeals for the Fourth Circuit
Decided June 7, 1972No. 71-1777, 71-1778PublishedCited by 18 opinions
1Opinion of the Court
CRAVEN, Circuit Judge:
Claiming that it qualified as a life insurance company under Section 801 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 801, Superior Life Insurance Company sought a refund of federal income taxes in the amount of $126,645.80 in the United States District Court for the District of South Carolina. From the judgment granting a full refund, 322 F.Supp. 921, the Government appeals. We find that the appeal is timely, and reaching the merits, we reverse.
I. TIMELINESS OF THE APPEAL
Taxpayer contends that this court lacks jurisdiction over the present case because the…
2Cases cited5 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- United States v. F. & M. Schaefer Brewing Co.Supreme Court of the United States · 1958
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
- Superior Life Insurnce v. United StatesDistrict Court, D. South Carolina · 1971
3Cited by18 opinions
- United States v. IndrelunasSupreme Court of the United States · 1973
- Caperton v. Beatrice Pocahontas Coal Co.Court of Appeals for the Fourth Circuit · 1978
- United States v. Consumer Life Insurance Co.Supreme Court of the United States · 1977
- Economy Finance Corp. v. United StatesCourt of Appeals for the Seventh Circuit · 1974
- Joseph Taylor v. W. L. SterrettCourt of Appeals for the Fifth Circuit · 1976
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