Legal Opinion

International Life Ins. Co. v. Commissioner

United States Tax Court

Decided February 17, 1969No. Docket No. 1307-67Published

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

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  3. Michaels v. CommissionerUnited States Tax Court · 1949
  4. Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
  5. 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.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API