Massachusetts Mutual Life Insurance v. United States

MEMORANDUM OPINION AND ORDER

BRADEN, Judge.

Although the United States Court of Appeals for the Federal Circuit has decided five federal income tax cases applying the “all events test,” established by the United States Supreme Court in United States v. Anderson, 269 U.S. 422, 431, 46 S.Ct. 131, 70 L.Ed. 347 (1926), none has addressed whether the right to receive supplemental premium income is “fixed” and when that amount of income can be determined with “reasonable accuracy” for purposes of calculating life insurance company taxable income--the core issues presented in this case.

PRELIMINARY…