United States v. Consumer Life Insurance Company

PETITIONER: United States
RESPONDENT: Consumer Life Insurance Company
LOCATION: Coeur d’Alene Indian Reservation

DOCKET NO.: 75-1221
DECIDED BY: Burger Court (1975-1981)
LOWER COURT:

CITATION: 430 US 725 (1977)
ARGUED: Dec 06, 1976
DECIDED: Apr 26, 1977

ADVOCATES:
E. Michael Masinter - for the Consumer Life Insurance Company
James R. Harper - for the First Railroad & Banking Company of Georgia
John B. Jones, Jr. - for Penn Security Life Insurance Company
Stuart A. Smith - for the United States

Facts of the case

Question

Media for United States v. Consumer Life Insurance Company

Audio Transcription for Oral Argument - December 06, 1976 in United States v. Consumer Life Insurance Company

Audio Transcription for Opinion Announcement - April 26, 1977 in United States v. Consumer Life Insurance Company

Warren E. Burger:

Mr. Justice Powell has three opinions of the Court to announce this morning.

Lewis F. Powell, Jr.:

The first of this involves three life insurance companies under the Internal Revenue Code.

The Federal Income Tax burden on life insurance companies is considerably lower than that imposed on other insurance companies.

A question in these cases is whether the taxpayers, three insurance companies, that write both life and non-life insurance qualify for this preferential treatment.

For a reason set forth in their opinion filed today with the clerk, we agree with the taxpayers that they do qualify.

The judgments in 75-1221 and 75-1285, the cases hereon on certiorari to the Court of Claims are affirmed.

The judgment of the Court of Appeals for the Fifth Circuit in 75-1260 is reversed.

Mr. Justice White has filed a dissenting opinion in which Mr. Justice Marshall has joined.