International Life Ins. Co. v. Commissioner
United States Tax Court
Petitioner acquired health and accident insurance policies from an insolvent insurance company and assumed the liabilities thereunder. 1. Held, the amount of unearned premiums and existing liabilities under the policies should not be netted against the gross cost to determine the consideration paid. 2. Held, further, the unearned premiums constituted income to the petititioner. 3. Held, further, the existing liabilities were neither income to petitioner nor includable in…
Read the full summary
Petitioner acquired health and accident insurance policies from an insolvent insurance company and assumed the liabilities thereunder. 1. Held, the amount of unearned premiums and existing liabilities under the policies should not be netted against the gross cost to determine the consideration paid. 2. Held, further, the unearned premiums constituted income to the petititioner. 3. Held, further, the existing liabilities were neither income to petitioner nor includable in "losses incurred" under sec 832(b)(5), I.R.C. 1954. 4. Held, further, no part of the consideration paid may be amortized by…
1Opinion of the Court
International Life Insurance Company (formerly State Insurance Co. of Kentucky), Petitioner v. Commissioner of Internal Revenue, Respondent
International Life Ins. Co. v. Commissioner
Docket No. 1307-67
United States Tax Court
51 T.C. 765; 1969 U.S. Tax Ct. LEXIS 191;
February 17, 1969, Filed
Decision will be entered under Rule 50.
Petitioner acquired health and accident insurance policies from an insolvent insurance company and assumed the liabilities thereunder.
1. Held, the amount of unearned premiums and existing liabilities under the policies should not be netted against the gross cost to…
2Cases cited24 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Michaels v. CommissionerUnited States Tax Court · 1949
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Commissioner of Internal Revenue v. Maurice L. KillianCourt of Appeals for the Fifth Circuit · 1963
19 more not listed; retrieve them via the Exa API.