Legal Opinion
The Prudential Insurance Company of America v. The United States
United States Court of Claims
Decided June 7, 1963No. 55-59PublishedCited by 39 opinions
1Opinion of the Court
DURFEE, Judge. *
This is an action to recover an alleged overpayment by plaintiff of Federal income tax for the calendar year 1949. Plaintiff is a mutual life insurance company organized under the laws of the State of New Jersey. In 1949, it was engaged in the insurance business in the United States and Canada.
During the year 1949, plaintiff paid a tax imposed by the Provinces of Ontario and Quebec of two percent on the insurance premiums collected that year from policyholders residing in the respective provinces. Plaintiff also paid the same tax imposed by the Dominion of Canada on premiums…
2Cases cited8 opinions
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- Crane v. CommissionerSupreme Court of the United States · 1947
- Bate Refrigerating Co. v. SulzbergerSupreme Court of the United States · 1895
- Commissioner of Internal Rev. v. Monarch Life Ins. Co.Court of Appeals for the First Circuit · 1940
- Jack W. Christner v. Poudre Valley Cooperative AssociationCourt of Appeals for the Tenth Circuit · 1956
3 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- F. W. Woolworth Co. v. CommissionerUnited States Tax Court · 1970
- Selman v. United StatesUnited States Court of Claims · 1974
- Union Pacific Railroad v. United StatesUnited States Court of Claims · 1975
- Richard Walter Ricker and Oswald Bryan Salyer v. The United StatesUnited States Court of Claims · 1968
- Estate of Nicol v. CommissionerUnited States Tax Court · 1971
34 more not listed; retrieve them via the Exa API.