Topic: by assuming numerous relatively small, independent risks th… · Go Syfert
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Topic #4905

5 canonical passages across 5 cases, quoted by 68 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from Clougherty Packing Company v. Commissioner of Internal Revenue.

#Case FlagCanonical passage Citers
1 Clougherty Packing Company v. Commissioner of Internal Revenue Anchor
ca9 · 1987
green “by assuming numerous relatively small, independent risks that occur randomly over time, the insurer smoothes out losses to match more closely its receipt of premiums.” 17
2 Securitas Holdings, Inc. v. Comm'r
tax · 2014
green “each insurance policy identified the insured, contained an effective period for the policy, specified what was covered by the policy, stated the premium amount, and was signed by an authorized representative of the company.” 15
3 Helvering v. Le Gierse
scotus · 1941
green “historically and commonly insurance 17 we reviewed the history of these provisions in avrahami, 149 t.c. at 175-76. - 32 - involves risk-shifting and risk-distributing.” 12
4 Hospital Corp. of Am. v. Commissioner
tax · 1997
green “must look beyond the formalities and consider the realities of the purported insurance transaction.” 12
5 R.V.I. Guar. Co. v. Comm'r
· 2015
green “each insurance policy identified the insured, contained an effective period for the policy, specified what was covered by the policy, stated the premium amount, and was signed by an authorized representative of the company.” 12

A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.

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