Legal Opinion

Federal Life Insurance Company (Mutual) v. United States

Court of Appeals for the Seventh Circuit

Decided December 24, 1975No. 75--1385PublishedCited by 16 opinions

1Per curiam

This appeal deals with a narrow question: when may a life insurance company deduct, under § 809(d)(12), 1 its expenses for commissions associated with premiums which are “deferred and uncollected” at the close of the tax year?

Plaintiff, a life insurance company, filed a suit for refund of taxes allegedly overpaid for the years 1965 and 1966. Although the complaint made somewhat broader claims for relief, it is agreed that the issue had been narrowed to the question just stated by the time the District Court dismissed the complaint.

There are difficulties involved in the income taxation of life…

2Cases cited9 opinions

  1. Jefferson Standard Life Insurance Company v. United States of America, (Two Cases). Jefferson Standard Life Insurance Company v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1969
  2. The Franklin Life Insurance Company v. United StatesCourt of Appeals for the Seventh Circuit · 1968
  3. Western National Life Insurance Company of Texas v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
  4. John E. Goodenow v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
  5. Western and Southern Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972

4 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. First Charter Financial Corp., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the First Circuit · 1982
  2. Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
  3. American Medical International, Inc. v. Secretary of Health, Education and WelfareCourt of Appeals for the D.C. Circuit · 1981
  4. Square D Company and Subsidiaries v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 2006
  5. Bell Federal Savings and Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994

11 more not listed; retrieve them via the Exa API.

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