Legal Opinion
World Service Life Insurance Company, as Corporate Successor to Stockman National Life Insurance Company v. United States
Court of Appeals for the Eighth Circuit
Decided January 8, 1973No. 72-1169PublishedCited by 9 opinions
1Opinion of the Court
LARAMORE, Senior Judge.
We are called upon in this case to review the question of whether the corporate taxpayer herein was entitled to certain net operating loss carryovers from a corporation which it acquired in a “taxfree” reorganization pursuant to section 368(a)(1)(C).1 Resolution of this question ultimately devolves to the validity of Treasury Regulation § 1.-382(b)~l (a)(2).
Plaintiff-Appellee, World Service Life Insurance, is the corporate successor to Stockman National Life Insurance Company and will be referred to herein as “Stockman”. Denver National Life Insurance Company, the…
2Cases cited7 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Helvering v. Minnesota Tea Co.Supreme Court of the United States · 1935
- Central Hanover B. & T. Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1947
- McMartin Industries, Inc. v. Richard P. Vinal, District Director of Internal Revenue, and United States of America, Intervenor-AppellantCourt of Appeals for the Eighth Circuit · 1971
- General Electric Company v. Melvin J. Burton, District Director of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Wortham MacHinery Company, a Wyoming Corporation v. The United States of AmericaCourt of Appeals for the Tenth Circuit · 1975
- Andres Iglesias v. The United States of AmericaCourt of Appeals for the Second Circuit · 1988
- Edward J. Prescott and Wanda D. Prescott v. Commissioner of Internal Revenue, L. W. Simpson and Shirley Simpson v. United StatesCourt of Appeals for the Eighth Circuit · 1977
- California Cosmetology Coalition v. RileyDistrict Court, C.D. California · 1994
- Consolidated Blenders, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1986
4 more not listed; retrieve them via the Exa API.