Legal Opinion
Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-Appellant
Court of Appeals for the Seventh Circuit
Decided October 14, 1992No. 91-3038, 91-3688PublishedCited by 36 opinions
1Opinion of the Court
EASTERBROOK, Circuit Judge.
Several subsidiaries of Sears, Roebuck & Co. sell insurance. One, Allstate Insurance CO., underwrote some of the risks of the parent corporation. Two others wrote mortgage insurance, promising to pay lenders if borrowers defaulted. Because Sears and all other members of the corporate group file a consolidated tax return, disputes about the tax consequences of these transactions affect the taxes of the entire *860group. The Commissioner of Internal Revenue assessed the, group with deficiencies exceeding $2.5 million for the tax years 1980-82. Whether the group owes this…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Brown v. HelveringSupreme Court of the United States · 1934
- Zenith Radio Corp. v. United StatesSupreme Court of the United States · 1978
19 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- United States v. Baxter International, IncorporatedCourt of Appeals for the Eleventh Circuit · 2003
- Johnson v. CommissionerUnited States Tax Court · 1997
- Amerco, Inc. Republic Insurance v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Whitehouse Hotel L.P. v. Comm'rUnited States Tax Court · 2008
- Abbott Laboratories, Zeneca, Inc., and Merck & Co., Inc. v. Cvs Pharmacy, Inc., Cvs Corp., and Cvs Revco D.S., Inc.Court of Appeals for the Seventh Circuit · 2002
31 more not listed; retrieve them via the Exa API.