Beneficial Life Ins. Co. v. Commissioner
United States Tax Court
During the years in issue, petitioner, a life insurance company, entered one assumption reinsurance transaction and seven indemnity reinsurance transactions. In each transaction, petitioner was the assuming or reinsuring company and received actual consideration from the ceding company in an amount less than the reserve liability actually assumed.
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During the years in issue, petitioner, a life insurance company, entered one assumption reinsurance transaction and seven indemnity reinsurance transactions. In each transaction, petitioner was the assuming or reinsuring company and received actual consideration from the ceding company in an amount less than the reserve liability actually assumed. Held: With respect to the assumption reinsurance transaction, petitioner must include in income an amount equal to the reserve liability actually assumed. Such amount is not affected by any revaluation of reserves made pursuant to petitioner's…
1Opinion of the Court
Beneficial Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Beneficial Life Ins. Co. v. Commissioner
Docket No. 3266-80
United States Tax Court
79 T.C. 627; 1982 U.S. Tax Ct. LEXIS 31; 79 T.C. No. 39;
October 4, 1982, Filed
Decision will be entered under Rule 155.
During the years in issue, petitioner, a life insurance company, entered one assumption reinsurance transaction and seven indemnity reinsurance transactions. In each transaction, petitioner was the assuming or reinsuring company and received actual consideration from the ceding company in an amount less…
2Cases cited9 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Anderson, Clayton & Co., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
- Beneficial Life Ins. Co. v. CommissionerUnited States Tax Court · 1982
- Kentucky Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1972
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