Prairie States Life Insurance v. United States’s Empirical Analysis
828 F.2d 1222 · 1987
Citation profile
6 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 14 later decisions (1 by the Supreme Court) — most recently September 2012
6 federal appellate · 2 district · 1 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.
Relationships
Relies on Crane v. Commissioner · United States v. Davis · Commissioner v. Tufts · Commissioner of Internal Revenue v. Idaho Power Company · Wells-Lee v. Commissioner of Internal Revenue
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.
“Because no statutory basis exists for allowing the ceding commission to be deducted as a current expense, the court resorts to generally recognized tax principles to determine the proper treatment of this payment. These principles dictate that costs incurred in the acquisition of an economic interest with an income-producing life extending substantially beyond the taxable year may not be ex-pensed but must be depreciated or amortized over useful life of the interest acquired.”
1 later decision quote this exact passage · from the majority“[T]axpayer may not reduce its income by treating the ceding commission either as a reduction of income under Section 809(c)(1) for ‘consideration arising out of reinsurance ceded,’ or as an underwriting expense deductible under Section 809(d)(12). Rather, taxpayer must amortize the commission as the cost of acquiring an income-producing asset with a useful life extending substantially beyond the current taxable year.”
1 later decision quote this exact passage · from the majority“specifically covers transactions similar to the one in this case, 'where the reinsured transfers to the reinsurer in connection with [an] assumption reinsurance transaction a net amount which is less than the increase in the reinsurer's reserves resulting from the transaction.”
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.