Legal Opinion
The Credit Life Insurance Company v. The United States
Court of Appeals for the Federal Circuit
Decided January 22, 1992No. 91-5028PublishedCited by 16 opinions
1Opinion of the Court
MICHEL, Circuit Judge.
The government appeals the United States Claims Court’s grant of summary judgment in favor of The Credit Life Insurance Company (“Credit Life” or “taxpayer”) in its suit for a partial refund of income taxes paid. Credit Life Ins. Co. v. United States, No. 585-84T (Cl.Ct. Oct. 17, 1990). The Claims Court erred in concluding that in claiming a bad debt deduction, taxpayer was entitled to rely on the conclusive presumption of worthlessness in the pertinent Treasury Regulation, 26 C.F.R. § 1.166-2(d)(1) (1973), despite not meeting the conditions set forth in the regulation.…
2Cases cited12 opinions
- United States v. Chicago, Milwaukee, St. Paul & Pacific R.Supreme Court of the United States · 1935
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
- Tipps v. CommissionerUnited States Tax Court · 1980
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
7 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Samueli v. Comm'rUnited States Tax Court · 2009
- Holmes v. United StatesUnited States Court of Federal Claims · 2011
- Herrmann v. United StatesUnited States Court of Federal Claims · 2015
- International Business Machines Corp. v. United StatesUnited States Court of Federal Claims · 1997
- Thurman v. CommissionerUnited States Tax Court · 1998
11 more not listed; retrieve them via the Exa API.