Indianapolis Life Ins. Co. and Subsidiary v. United States

AMENDED ENTRY ON CROSS-MOTIONS FOR SUMMARY JUDGMENT *

HAMILTON, District Judge.

This case is only the most recent round in the economic and political competition between two segments of the life insurance industry — mutual life insurance companies and stock life insurance companies. In 1984, Congress rewrote § 809 of the Internal Revenue Code, 26 U.S.C. § 809, to address what it perceived to be an unfair difference between the taxation of income of mutual life insurance companies and stock life insurance companies. As explained in detail below, the chosen solution provides a case study in the…