Beneficial Life Ins. Co. v. Commissioner
United States Tax Court
During the years in issue, petitioner, a life insurance company, entered one assumption reinsurance transaction and seven indemnity reinsurance transactions. In each transaction, petitioner was the assuming or reinsuring company and received actual consideration from the ceding company in an amount less than the reserve liability actually assumed.
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During the years in issue, petitioner, a life insurance company, entered one assumption reinsurance transaction and seven indemnity reinsurance transactions. In each transaction, petitioner was the assuming or reinsuring company and received actual consideration from the ceding company in an amount less than the reserve liability actually assumed. Held: With respect to the assumption reinsurance transaction, petitioner must include in income an amount equal to the reserve liability actually assumed. Such amount is not affected by any revaluation of reserves made pursuant to petitioner's…
1Opinion of the Court
Fay, Judge-.
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
Year Deficiency
1972 . $1,224,303
1973 . 1,727,061
1974 . 1,871,501
1975 . 770,916
1976 . 1,326,677
After concessions, the issues remaining concern the proper tax treatment to be accorded certain reinsurance transactions. Those issues, delineated more fully infra, are (1) whether the assuming or reinsuring company recognizes income to the extent the reserve liabilities assumed exceed the initial consideration received; (2) if so, whether such excess is currently deductible or represents the acquisition of…
2Cases cited8 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Anderson, Clayton & Co., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
- Kentucky Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1972
- Mutual Savings Life Insurance Co., Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1974
3 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
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- Snap-Drape v. CommissionerUnited States Tax Court · 1995
- Prairie States Life Insurance Co. v. United StatesCourt of Appeals for the Eighth Circuit · 1987
- Oxford Life Insurance Company v. United StatesCourt of Appeals for the Ninth Circuit · 1986
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