Modern American Life Ins. Co. v. Commissioner
United States Tax Court
M & P guaranteed payments to certain of their policyholders in 1978 and 1979. Held, the payments are properly characterized as policyholder dividends under sec. 809(d)(3) of the Internal Revenue Code. Held, further, the reserves established for the payment of these guaranteed payments are policyholder dividend reserves.
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M & P guaranteed payments to certain of their policyholders in 1978 and 1979. Held, the payments are properly characterized as policyholder dividends under sec. 809(d)(3) of the Internal Revenue Code. Held, further, the reserves established for the payment of these guaranteed payments are policyholder dividend reserves. Held, further, M is entitled to an operations loss carryback under sec. 812 of the Internal Revenue Code, to 1978 and 1979 based upon a total operations loss of $ 1,418,441 in 1981.
1Opinion of the Court
Parr, Judge:
Respondent determined the following deficiencies against Modern American Life Insurance Co. (petitioner) in the following years:
Year Deficiency
1978 . $463,604
1979 . 676,450
Respondent also determined the following deficiencies against Progressive National Life Insurance Co. (Progressive) in the following years:
Year Deficiency
1978 . $387,343
1979 . 350,376
Modern American Life Insurance Co., formerly known as Modern Security Life Insurance Co., merged with Progressive National Life Insurance Co. on September 30, 1983. On April 13, 1987, Modern American Life Insurance Co. moved under…
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- Republic National Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
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