Atlas Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner is entitled to include in its reserves required by law the reserve required to cover liability under the coupons attached to the guaranteed premium reduction policies issued by petitioner. Standard Life Ins. Co. of America,13 B.T.A. 13; affd., 47 Fed.(2d) 218; Farmers Life Ins. Co.,27 B.T.A. 423. 2. Rental value of space occupied by petitioner in its home office building is not required to be included in gross income. Independent Life Ins.
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1. Petitioner is entitled to include in its reserves required by law the reserve required to cover liability under the coupons attached to the guaranteed premium reduction policies issued by petitioner. Standard Life Ins. Co. of America,13 B.T.A. 13; affd., 47 Fed.(2d) 218; Farmers Life Ins. Co.,27 B.T.A. 423. 2. Rental value of space occupied by petitioner in its home office building is not required to be included in gross income. Independent Life Ins. Co.,17 B.T.A. 757; affd., 67 Fed.(2d) 470. 3. Rent received from tenants of home office building, which was erected by petitioner on land…
1Opinion of the Court
*755OPINION.
Matthews :
The first issue for determination is whether there was error in the respondent’s exclusion from the “ reserve funds required by law”, in the calculation of the petitioner’s gross income, of amounts held by petitioner in its reserves to satisfy its obligations on coupons on certain policies of life insurance known as guaranteed premium reduction policies, where premium reduction credits evidenced by coupons had been left with the petitioner to accumulate in accordance with the provisions of the policies. The applicable statutory provisions are section 245 (a), identical in…
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- Burnet v. Coronado Oil & Gas Co.Supreme Court of the United States · 1932
- Weston and Others v. the City Council of CharlestonSupreme Court of the United States · 1829
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- Thomas v. GaySupreme Court of the United States · 1898
- Gillespie v. OklahomaSupreme Court of the United States · 1922
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3Cited by3 opinions
- Hobart Iron Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Atlas Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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