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← 28 FEDCL 602 - Travelers Insurance v. United States

Travelers Insurance v. United States’s Empirical Analysis

1993

Citation profile

4
cited by 4 later decisions
August 2006
most recently cited

Relationships

Applies 26 U.S.C. § 841 · 26 U.S.C. § 904

Relies on Morton v. Mancari · Ruckelshaus v. Monsanto Co. · Santiago v. United States · Schuster's Express, Inc. v. Commissioner · Schuster's Express, Inc. v. C. I. R

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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Under defendant's computation, [s]ection 907(b) imposes the greatest restriction upon Travelers' allowable foreign tax credit related to the Indonesian oil venture. Thus, [s]ection 907(b) provides the lesser foreign tax credit under [s]ection 901(a), and is the operative limitation in this case.”
    1 later decision quote this exact passage
  2. “[i]n reality, the policyholders' share exclusion is the required interest portion of the reserve deduction which is fully recouped by the corresponding decrease in the year-end reserves under [s]ection 810.”
    1 later decision quote this exact passage
  3. “the legislative history indicates that Congress specifically designated the policyholders' share as an exclusion after initially labeling it as a deduction.”
    1 later decision quote this exact passage

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.