National Life Insurance v. Commissioner’s Empirical Analysis
103 F.3d 5 · 1996
Citation profile
10 federal appellate ·
How this case has been cited
Cited by 14 later decisions — most recently August 2013
10 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 26 U.S.C. § 481 · 26 U.S.C. § 7701 · 26 U.S.C. § 808 · 26 U.S.C. § 811
Relies on United States v. Ron Pair Enterprises, Inc. · Connecticut National Bank v. Germain · Red Lion Broadcasting Co. v. Federal Communications Commission · Norman Peterson Marital Trust v. Commissioner of Internal Revenue · Belloff v. Commissioner
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) General rule.- — In computing the taxpayer’s taxable income for any taxable year (referred to in this section as the “year of the change”) - (1) if such computation is under a method of accounting different from the method under which the taxpayer’s taxable income for the preceding taxable year was computed, then (2) there shall be taken into account those adjustments which are determined to be necessary solely by reason of the change in order to prevent amounts from being duplicated or omitted....”
3 later decisions quote this exact passage · from the majority“[U]nder National Life’s guaranteed dividend policy, National Life becomes obligated to pay one-twelfth of the dividend each month.” (emphasis added)); id. (”[I]f a policy terminated three months before the anniversary date ... the policyholder would be entitled to seventy-five percent ... of the dividend for that policy year.”
1 later decision quote this exact passage · from the majority“Because different tax accounting methods provide for different dates on which income or deductions are recognized, a switch in accounting methods can create a situation in which a taxpayer is able to deduct the same expense--or is required to recognize the same income--in two separate tax years.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.