1. Home
  2. Browse Decisions
  3. F.2d
  4. 882 F.2d
  5. 882 F.2d 832 (1989)
 

PRUDENTIAL INS. CO. OF AMERICA v. C.I.R.

No. 89-1259.

882 F.2d 832 (1989)

The PRUDENTIAL INSURANCE COMPANY OF AMERICA, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Third Circuit.

Decided August 22, 1989.

Attorney(s) appearing for the Case

Michael F. Kelleher (argued), Irene Price, and Kathleen M. Niles, Groom and Nordberg Chartered, Washington, D.C., for appellant (Michael R. Chesman and Terry J. Hartzel, Prudential Ins. Co. of America, of counsel.)

James I.K. Knapp, Acting Asst. Atty. Gen., Gary R. Allen, Chief Appellate Section, Robert S. Pomerance, and Robert W. Metzler (argued), Attys. Tax Div., Department of Justice, Washington, D.C., for appellee.

Before GIBBONS, Chief Judge, and HUTCHINSON, Circuit Judge, and WOLIN, District Judge.

OPINION OF THE COURT

GIBBONS, Chief Judge:

The Prudential Insurance Company of America appeals from an adverse United States Tax Court decision. The sole issue presented is whether receipt by an insurance company of prepayment charges upon the retirement of certain corporate mortgages should be characterized as long-term capital gain excluded from "gross investment income" within the meaning of section 804(b) of the Internal Revenue Code. The Tax Court held...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases