Commissioner of Internal Revenue v. Standard Life & Accident Insurance Company’s Empirical Analysis
1977
Citation profile
40 federal appellate · 3 district · 2 state decisions
How this case has been cited
Cited by 118 later decisions (5 by the Supreme Court) — most recently March 2010 · most notably Sisler v. Gannett Co., Inc. (1986), Colonial American Life Insurance v. Commissioner (1989)
40 federal appellate · 3 district · 2 state decisions
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.
Appellate journey
reviewedStandard Life & Accident Insurance v. Commissioner (from Tenth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 818 · 26 U.S.C. § 832
Relies on Ohio Bureau of Employment Services v. Hodory · Gotthelf v. Commissioner · Phelps Dodge Corp. v. AFL-CIO Joint Negotiating Committee · Johnson v. United States · United States v. Consumer Life Insurance Co.
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 118 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“unless the NAIC procedures are inconsistent with accrual accounting rules which require different treatment under the Code. On page 161 of 433 U.S. on page 2531 of 97 S.Ct. supra, the Court, after noting that the accounting approach adopted by the NAIC for purposes of preparing the Annual Statement is firmly anchored to § 818(a) of the Code which establishes a preference for NAIC accounting methods, stated in footnote 24, to-wit: 58 Evidence of congressional respect of NAIC accounting methods is not limited to the portion of the Code concerning life insurance companies. In defining”
3 later decisions quote this exact passage · from the concurrence“Under normal accounting rules, unpaid premiums would simply be ignored. They would not be properly accruable since the company has no legal right to collect them. Nevertheless, for the past century, insurance companies have added an amount equal to the net valuation portion of unpaid premiums to their reserves, with an offsetting addition to assets. State law uniformly requires this treatment of unpaid premiums, as does the accounting form issued by the National Association of Insurance Commissioners (NAIC). This national organization of state regulatory officials, which acts on behalf of the various state insurance departments, performs audits on insurance companies like respondent which do business in many States. The NAIC accounting form, known in the industry as the “Annual Statement,” is used by respondent for its financial reporting. In effect, in calculating its reserves, the company must treat these premiums to some extent as if they had been paid.”
2 later decisions quote this exact passage · from the majority“policy and other contract liability requirements”
2 later decisions quote this exact passage · from the concurrence
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.