Legal Opinion
American Electric Power Company, Inc. v. United States
Court of Appeals for the Sixth Circuit
Decided April 28, 2003No. 01-3495PublishedCited by 35 opinions
1Opinion of the CourtGilman, J., joined by Cole, J.,
DAVID A. NELSON, J. (pp. 745 - 747), delivered a separate concurring opinion.
OPINION
GILMAN, Circuit Judge.
American Electric Power Company, Inc. (AEP) implemented a corporate-owned life insurance (COLI) plan in 1990 that caused it to purchase policies on the lives of over 20,000 of its employees. In 1996, AEP deducted from its federal income tax approximately $66 million in interest due on loans made against the policies. The IRS disallowed the deduction and assessed AEP with an additional $25 million in taxes for the year in question. AEP paid the additional tax under protest and then sued…
2Cases cited16 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Jan M. Sexton Salmi v. Secretary of Health and Human ServicesCourt of Appeals for the Sixth Circuit · 1985
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Kerry W. Illes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
11 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Wal-Mart Stores, Inc. v. AIG Life InsuranceSupreme Court of Delaware · 2004
- New Phoenix Sunrise Corp. v. Comm'rUnited States Tax Court · 2009
- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- The Dow Chemical Company v. United StatesCourt of Appeals for the Sixth Circuit · 2006
- Wal-Mart Stores, Inc. v. AIG Life InsuranceCourt of Chancery of Delaware · 2005
30 more not listed; retrieve them via the Exa API.