Malone & Hyde, Inc., and Subsidiaries v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that a reinsurance arrangement was not bona fide because the captive was undercapitalized and the parent guaranteed the captive’s obligations to an unrelated insurer
• holding that a reinsurance arrangement was not bona fide because the captive was undercapitalized and the parent guaranteed the captive's obligations to an unrelated insurer
• holding that a reinsurance arrangement was not bona fide because the captive was undercapitalized and the parent guaranteed the captive’s obligations to an unrelated insurer
• rejecting \economic family\ theory but ruling against deductibility of payments to captive based on facts and circumstances
• rejecting “economic family” theory but ruling against deductibility of payments to captive based on facts and circumstances
• rejecting “economic family” theory but ruling against deductibility of payments to captive based on facts and circumstances

Source: CourtListener parenthetical corpus (CC0).