Legal Opinion
Humana Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided July 27, 1989No. 88-1403PublishedCited by 43 opinions
1Opinion of the Court
BOYCE F. MARTIN, Jr., Circuit Judge.
Humana Inc. and its wholly owned subsidiaries with which it files a consolidated federal income tax return appeal the decision of the United States Tax Court determining deficiencies against them with respect to their 1976-1979 fiscal years on the basis that: 1) sums paid by Humana Inc. to its captive insurance subsidiary, Health Care Indemnity, on its own behalf and on behalf of other wholly owned subsidiaries did not constitute deductible insurance premiums under the Internal Revenue Code § 162(a) (1954), and 2) such payments are not deductible under the…
2Cases cited22 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Helvering v. Le GierseSupreme Court of the United States · 1941
17 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Transcore v. Electronic Transaction Consultants Corp.Court of Appeals for the Federal Circuit · 2009
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Amerco v. CommissionerUnited States Tax Court · 1991
- Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1992
38 more not listed; retrieve them via the Exa API.