Cologne Life Reinsurance Co. v. Commissioner
United States Tax Court
Held, the deduction provided by sec. 809(d)(5), I.R.C. 1954, is applicable to P's risk premium reinsurance.
1Opinion of the Court
OPINION
Whitaker, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Taxable year Deficiency
1974 .$123,141
1975 . 123,433
1976 . 133,077
1977 . 170,683
The sole issue for decision is whether petitioner is entitled to the deduction under section 809(d)(5)1 with respect to its risk premium reinsurance contracts.
This case was submitted fully stipulated. The stipulation of facts and exhibits attached thereto are so found.
At the time it filed the petition, Cologne Life Reinsurance Co. was a corporation organized under the laws of the State of Connecticut with its…
2Cases cited11 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- United States v. Consumer Life Insurance Co.Supreme Court of the United States · 1977
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
- Service Bolt & Nut Co. Profit Sharing Trust v. CommissionerUnited States Tax Court · 1982
- Warrensburg Bd. & Paper Corp. v. CommissionerUnited States Tax Court · 1981
6 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Merit Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Cologne Life Reinsurance Co. v. CommissionerUnited States Tax Court · 1983