National Sav. Life Ins. Co. v. Commissioner
United States Tax Court
Petitioner, a life insurance company under subch. L, I.R.C. 1954, acquired life insurance reserves from Progressive, also a life insurance company under subch. L, I.R.C. 1954, pursuant to a statutory merger. Petitioner had elected under sec. 818(c), I.R.C. 1954, to revalue its preliminary term reserves, while Progressive had not so elected.
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Petitioner, a life insurance company under subch. L, I.R.C. 1954, acquired life insurance reserves from Progressive, also a life insurance company under subch. L, I.R.C. 1954, pursuant to a statutory merger. Petitioner had elected under sec. 818(c), I.R.C. 1954, to revalue its preliminary term reserves, while Progressive had not so elected. Held, sec. 381, I.R.C. 1954, does not require petitioner to add the acquired reserves to its sec. 810, I.R.C. 1954, opening balance in the revalued amount; rather, petitioner must include the unrevalued dollar balance of the acquired reserves in its…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
1972 .$251,979
1973 . 127,952
1974 . 124,309
After agreements between and concessions by the parties, the issues for decision are:(1) Whether petitioner is required to revalue life insurance reserves acquired in a statutory merger before adding such reserves to its own revalued opening balance of reserves for the year in which the merger took place, and, if so, whether petitioner is entitled to a deduction as an adjustment to reflect the revaluation;(2) Whether petitioner may utilize the…
2Cases cited11 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Waterman Steamship Corp. v. United StatesSupreme Court of the United States · 1965
- Taft v. HelveringSupreme Court of the United States · 1940
- Lincoln National Life Insurance v. United StatesUnited States Court of Claims · 1978
6 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Austin v. CommissionerUnited States Tax Court · 1960
- USAA Life Ins. Co. v. CommissionerUnited States Tax Court · 1990
- National Sav. Life Ins. Co. v. CommissionerUnited States Tax Court · 1985
- USAA Life Ins. Co. v. CommissionerUnited States Tax Court · 1990