Legal Opinion
The Union Central Life Insurance Company, Cross-Appellant v. Commissioner of Internal Revenue, Cross-Appellee
Court of Appeals for the Sixth Circuit
Decided November 16, 1983No. 82-1380, 82-1411PublishedCited by 12 opinions
1Opinion of the Court
CONTIE, Circuit Judge.
The Commissioner of Internal Revenue appeals, and Union Central Life Insurance Company cross-appeals, from a Tax Court decision construing the Life Insurance Company Income Tax Act of 1959. The Tax Court, 77 Tax Court 845, held that part of an Ohio franchise tax paid by the company was deductible under 26 U.S.C. § 804(c)(1) rather than under 26 U.S.C. § 809 as contended by the Commissioner. The court also held, despite Union Central’s protestations, that approximately 130 acres of unimproved land adjacent to the company’s home office was an asset under 26 U.S.C. §…
2Cases cited9 opinions
- Hotel Equities Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1976
- Kittredge v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1937
- Williams v. Port Authority of New York & New JerseySupreme Court of the United States · 1979
- Francis E. Gartrell and Mabel L. Gartrell v. United StatesCourt of Appeals for the Sixth Circuit · 1980
- Liberty National Life Insurance Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-Cross (Two Cases)Court of Appeals for the Fifth Circuit · 1972
4 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Ohio National Life Insurance v. United StatesUnited States Court of Claims · 1986
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- Northwestern Mutual Life Insurance v. United StatesUnited States Court of Claims · 1985
- Principal Mutual Life Insurance v. United StatesUnited States Court of Claims · 1992
- Southwestern Life Insurance v. United StatesUnited States Court of Claims · 1985
7 more not listed; retrieve them via the Exa API.