Legal Opinion
Life Insurance v. United States
United States Court of Claims
Decided February 28, 1989No. 744-85 TPublishedCited by 2 opinions
1Opinion of the Court
OPINION
WIESE, Judge.
Under the Life Insurance Company Income Tax Act of 1959, Pub.L. No. 86-69, 73 Stat. 115, which amended sections 801-820 of the Internal Revenue Code of 1954, life *360insurance companies enjoy a deferral of federal income taxes on one-half of the amount by which their gain from operations (meaning, essentially, the income deriving both from risk underwriting and investment activities less allowable deductions) exceeds their gain from investment activities alone (i.e., investment income less allowable deductions). 26 U.S.C. § 802(b) (1982). Given this taxing scheme, expenses…
2Cases cited4 opinions
- Liberty Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-Appellee. Liberty Life Insurance Company, Plaintiff-Appellant-Cross-Appellee v. United States of America, Defendant-Appellee-Cross-AppellantCourt of Appeals for the Fourth Circuit · 1979
- Ohio National Life Insurance v. United StatesUnited States Court of Claims · 1986
- Northwestern Mutual Life Insurance v. United StatesUnited States Court of Claims · 1985
- Liberty National Life Insurance Company, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Eleventh Circuit · 1987
3Cited by2 opinions
- Principal Mutual Life Insurance v. United StatesUnited States Court of Claims · 1992
- Travelers Insurance v. United StatesUnited States Court of Federal Claims · 1993