Legal Opinion
Allied Fidelity Corporation, F/k/a, William E. Roe, Allied Agents, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided March 23, 1978No. 77-1415PublishedCited by 26 opinions
1Opinion of the Court
GRANT, Senior District Judge.
The single issue presented in this appeal is whether the wholly owned subsidiary of appellant, the Allied Fidelity Insurance Corporation (Allied), is entitled to be classified as an insurance company under the provisions of 26 U.S.C. §§ 831 and 832.
Allied, an Indiana corporation whose principal offices are located in Indianapolis, Indiana, exists as a wholly owned subsidiary of the taxpayer, Allied Fidelity Corporation. Since 1969 Allied has engaged primarily in the business of writing fidelity and surety bonds. During 1971, about 91% of Allied’s business was in…
2Cases cited15 opinions
- Stack v. BoyleSupreme Court of the United States · 1952
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Taylor v. TaintorSupreme Court of the United States · 1873
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Helvering v. Le GierseSupreme Court of the United States · 1941
10 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Carnation Co. v. CommissionerUnited States Tax Court · 1978
- Bruno v. CommissionerUnited States Tax Court · 1978
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
- T.F.H. Publications, Inc. v. CommissionerUnited States Tax Court · 1979
- R.V.I. Guar. Co. v. Comm'rUnited States Tax Court · 2015
21 more not listed; retrieve them via the Exa API.