Legal Opinion
Amerco, Inc. Republic Insurance v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided November 5, 1992No. 91-70732PublishedCited by 29 opinions
1Opinion of the Court
FERNANDEZ, Circuit Judge:
AMERCO and a number of its subsidiaries (AMERCO Group) purchased insurance policies from Republic Western Insurance Company (Republic) and deducted the pre-: miums for income tax purposes. Republic was a subsidiary of AMERCO. The Commissioner of Internal Revenue (Commissioner) determined that because of the relationships among the parties the transactions did not constitute insurance. A notice of deficiency was issued by the Commissioner, and AMERCO petitioned the Tax Court for a redetermination. The Tax Court found that the transactions were insurance. 1 It,…
2Cases cited13 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Carnation Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
- Clougherty Packing Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Stanley D. Pomarantz and Linda Burnett Pomarantz v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
8 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Cluck v. CommissionerUnited States Tax Court · 1995
- Custom Chrome, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Steven G. Hill Parilea Hill v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
- Rlc Industries Co. And Subsidiaries, Successor to Roseburg Lumber Co. And Subsidiaries v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Neil M. Baizer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2000
24 more not listed; retrieve them via the Exa API.