Continental Bankers Life Ins. Co. v. Commissioner
United States Tax Court
F directly owned 100 percent of the stock of both P (a life insurance company) and C, and 56.32 percent of the stock of CBN. C directly owned 20 percent of the stock in CBN. P acquired all of F's stock and C's stock in CBN with property.
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F directly owned 100 percent of the stock of both P (a life insurance company) and C, and 56.32 percent of the stock of CBN. C directly owned 20 percent of the stock in CBN. P acquired all of F's stock and C's stock in CBN with property. Held, P's acquisitions of F's stock and C's stock in CBN are treated as distributions in redemption of P's stock under sec. 304(a)(1). Held, further, P made distributions under sec. 815 resulting in phase III taxable income under sec. 802(b)(3) to the extent made out of its policyholders' surplus account. P claimed an operations loss carryover deduction in…
1Opinion of the Court
Continental Bankers Life Insurance Company of the South, Petitioner v. Commissioner of Internal Revenue, Respondent
Continental Bankers Life Ins. Co. v. Commissioner
Docket Nos. 3643-85, 29843-85
United States Tax Court
93 T.C. 52; 1989 U.S. Tax Ct. LEXIS 102; 93 T.C. No. 6;
July 12, 1989; As corrected August 21, 1989 July 12, 1989, Filed
Decisions will be entered under Rule 155.
F directly owned 100 percent of the stock of both P (a life insurance company) and C, and 56.32 percent of the stock of CBN. C directly owned 20 percent of the stock in CBN. P acquired all of F's stock and C's stock in CBN…
2Cases cited20 opinions
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- Crown v. CommissionerUnited States Tax Court · 1981
- Niedermeyer v. CommissionerUnited States Tax Court · 1974
- Fehrs Finance Co. v. CommissionerUnited States Tax Court · 1972
- Fehrs Finance Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Eighth Circuit · 1973
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