Jefferson Standard Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Assets held against a liability "present value of amounts not yet due on supplementary contracts not involving life contingencies" held not to be "reserve funds required by law" within the meaning of section 203(a)(2) of the Revenue Act of 1932. 2. Interest payments made by the petitioner to beneficiaries on proceeds of matured policies left with the company (option 3) under contracts to pay interest "at such rate as the Directors of the Company may declare, but not less…
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1. Assets held against a liability "present value of amounts not yet due on supplementary contracts not involving life contingencies" held not to be "reserve funds required by law" within the meaning of section 203(a)(2) of the Revenue Act of 1932. 2. Interest payments made by the petitioner to beneficiaries on proceeds of matured policies left with the company (option 3) under contracts to pay interest "at such rate as the Directors of the Company may declare, but not less than 3 1/2% per annum", held to be legal deductions from gross income. 3. Interest payments included in installment…
1Opinion of the Court
JEFFERSON STANDARD LIFE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Jefferson Standard Life Ins. Co. v. Commissioner
Docket No. 89422.
United States Board of Tax Appeals
44 B.T.A. 314; 1941 BTA LEXIS 1343;
April 29, 1941, Promulgated
1. Assets held against a liability "present value of amounts not yet due on supplementary contracts not involving life contingencies" held not to be "reserve funds required by law" within the meaning of section 203(a)(2) of the Revenue Act of 1932.
2. Interest payments made by the petitioner to beneficiaries on proceeds of matured…
2Cases cited10 opinions
- Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
- United States v. Boston InsuranceSupreme Court of the United States · 1925
- Helvering v. Illinois Life InsuranceSupreme Court of the United States · 1936
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