The U.S. Supreme Court case Commissioner of Internal Revenue v. Standard Life & Accident Insurance Co., 1976, revolved around the interpretation and application of a provision in the United States' tax code regarding life insurance companies. The issue at hand was whether or not Standard Life & Accident Insurance Company could deduct policyholder dividends from its taxable income for the years 1963 and 1964 under Section 809(d)(11) of the Internal Revenue Code of 1954, which allows such deductions if they are paid out during that year or declared to be payable to policyholders who held policies on December 31st with payment deferred until after that date but within one year. The court ruled in favor of Standard Life & Accident Insurance Co., stating that it had correctly interpreted this section's language when it deducted these dividends from its taxable income because they were "paid" when credited to policyholder accounts even though actual distribution might occur later.

In the dissenting opinion for Commissioner of Internal Revenue v. Standard Life & Accident Insurance Co., Justice Blackmun argued that the majority's interpretation of Section 801(b)(1)(C) and (b)(2) was incorrect. He believed that Congress intended to provide a tax advantage only to those insurance companies whose primary and predominant business is life insurance, not just any company with significant involvement in it. The majority’s decision allowed companies like Standard Life, which had substantial non-life-insurance operations, to benefit from this provision unjustly. Furthermore, he disagreed with their view on what constitutes 'assets', arguing that policy loans should be included as they are an integral part of an insurer's assets portfolio. This would have resulted in a higher percentage of reserves being allocated towards non-life-insurance policies for Standard Life thus disqualifying them from receiving the tax benefits under section 801(a). Therefore, according to him, the Court misinterpreted Congressional intent by allowing such companies access to these benefits while also incorrectly defining 'assets' within this context.