National States Ins. Co. v. Commissioner
United States Tax Court
Petitioner, an insurance company, issued guaranteed renewable health and accident insurance policies during the years in issue. Under these level premium policies, petitioner could neither cancel nor refuse to renew coverage for life or to age 65, but reserved the right to adjust the scale of premiums by class based on experience.
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Petitioner, an insurance company, issued guaranteed renewable health and accident insurance policies during the years in issue. Under these level premium policies, petitioner could neither cancel nor refuse to renew coverage for life or to age 65, but reserved the right to adjust the scale of premiums by class based on experience. Petitioner estimated its unearned premium reserve on the basis of gross pro rata unearned premiums and the additional reserve on the mid-terminal basis. The additional reserve, which reflected petitioner's long-term obligation stemming from the guaranteed renewable…
1Opinion of the Court
Wilbur, Judge:
Respondent determined deficiencies and an addition to petitioner’s Federal income taxes as follows:
Addition to tax Year Deficiency under sec. 6653(a)
1973 .$56,556.24
1974 . 169,687.01 $8,484.35
1975 . 157,315.55
1976 . 177,534.31
After concessions, the sole question presented for decision is whether petitioner qualified as a life insurance company during the years in issue under the provisions of section 801(a).1 Specifically, we must decide whether petitioner’s individual accident and health policies were "guaranteed renewable” within the meaning of section 1.801-3(d), Income Tax…
2Cases cited2 opinions
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
- Group Life & Health Insurance Company v. United StatesCourt of Appeals for the Fifth Circuit · 1971
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- National States Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1985
- USAA Life Ins. Co. v. CommissionerUnited States Tax Court · 1990
- National Sav. Life Ins. Co. v. CommissionerUnited States Tax Court · 1985
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