Legal Opinion
John A. Greene, Receiver for the Great Global Assurance Company, in Liquidation v. United States
Court of Appeals for the Federal Circuit
Decided August 16, 1999No. 99-5016PublishedCited by 8 opinions
1Opinion of the Court
LOURIE, Circuit Judge.
John A. Greene, receiver for the Great Global Assurance Company (GGAC), appeals from the decision of the United States Court of Federal Claims that dismissed his tax refund claim on the ground that the statute of limitations had run. See Green v. United States, 42 Fed. Cl. 18 (1998). Because we conclude that the trial court misconstrued the statute, we reverse.
BACKGROUND
During the 1983 taxable year, GGAC was a life insurance company subject to the “three-phase” taxation procedure of the Life Insurance Company Income Tax Act of 1959. See Pub.L. No. 86-69, 73 Stat. 112…
2Cases cited6 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Suramerica de Aleaciones Laminadas, C.A. v. United StatesCourt of Appeals for the Federal Circuit · 1992
- Kaltreider Construction, Inc. v. United StatesCourt of Appeals for the Third Circuit · 1962
- Sun Chemical Corp., a Delaware Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1983
1 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Electrolux Holdings, Inc. v. United StatesUnited States Court of Federal Claims · 2006
- Browning Ferris Industries, Inc. & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2007
- Greene v. United StatesUnited States Court of Federal Claims · 2004
- Greene v. United StatesCourt of Appeals for the Federal Circuit · 2006
- John A. Greene, Receiver for the Great Global Assurance Company v. United StatesCourt of Appeals for the Federal Circuit · 2006
3 more not listed; retrieve them via the Exa API.