Legal Opinion
Modern Life & Accident Insurance Company v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided January 14, 1970No. 36_1PublishedCited by 10 opinions
1Opinion of the Court
FAIRCHILD, Circuit Judge.
Taxpayer had for a number of years reported and computed its income tax as if it were a life insurance company as defined in 26 U.S.C. § 801, and therefore subject to the tax imposed by § 802. In 1965, the commissioner decided that taxpayer was not a life insurance company under § 801, but a mutual insurance company taxable under § 821. He determined deficiencies for 1959, ’60, ’61, and ’62 by computing the tax under the latter section.
In a proceeding before the tax court, taxpayer conceded it was not taxable as a life insurance company, but contended that it was an…
2Cases cited6 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- United States v. South-Eastern Underwriters Assn.Supreme Court of the United States · 1944
- United States v. PelzerSupreme Court of the United States · 1941
- Federal Trade Commission v. Travelers Health Ass'nSupreme Court of the United States · 1960
- Mutual Fire Ins. Co. of Germantown v. United StatesCourt of Appeals for the Third Circuit · 1944
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Hill v. State Farm Mutual Automobile InsuranceCalifornia Court of Appeal · 2008
- National Chiropractic Insurance Co. v. United StatesCourt of Appeals for the Eighth Circuit · 1974
- National Chiropractic Insurance Co. v. United StatesDistrict Court, S.D. Iowa · 1973
- California State Automobile Ass'n v. Franchise Tax BoardCalifornia Court of Appeal · 1987
- Oklahoma State Union of Farmers Educational & Cooperative Union v. CommissionerUnited States Tax Court · 1977
5 more not listed; retrieve them via the Exa API.