Home Group Inc 11502-77 v. Commissioner of Internal Revenue’s Empirical Analysis
875 F.2d 377 · 1989
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 26 later decisions — most recently September 2013 · most notably Howard v. Adkison (1989), Harris v. Commissioner (1992)
6 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. § 7482 · 26 U.S.C. § 832
Relies on Pierce v. Underwood · Anthony v. United States · Thor Power Tool Company v. Commissioner of Internal Revenue · Barefoot v. Estelle · Brown v. Helvering
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(6) Expenses incurred. — The term “expenses incurred” means all expenses shown on the annual statement approved by the National Association of Insurance Commissioners, and shall be computed as follows: To all expenses paid during the taxable year, add expenses unpaid at the end of the taxable year and deduct expenses unpaid at the end of the preceding taxable year. For the purpose of eomputing the taxable income subject to the tax imposed by section 831, there shall be deducted from expenses incurred (as defined in this paragraph) all expenses incurred which are not allowed as deductions by subsection (c).”
1 later decision quote this exact passage · from the majority“An accounting practice for bookkeeping purposes is not necessarily what the Code allows for tax accounting purposes.”), and Western Casualty & Surety Co. v. Comm’r of Internal Revenue, 571 F.2d 514 , 517 (10th Cir.1978). We need not opine whether bad-faith punitive damages would conflict with the”
1 later decision quote this exact passage · from the majority“the premiums earned on insurance contracts during the taxable year less losses incurred and expenses incurred. [Petitioner's emphasis supplied.]”
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.