John Hancock Life Ins. Co. (U.S.A.) v. Comm'r
United States Tax Court
JH is primarily in the business of selling life insurance policies, annuities, long-term care insurance, and other retirement services. To fulfill its contractual obligations under these services JH invests the premiums it receives. In 1979 JH began investing in leveraged leases.
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JH is primarily in the business of selling life insurance policies, annuities, long-term care insurance, and other retirement services. To fulfill its contractual obligations under these services JH invests the premiums it receives. In 1979 JH began investing in leveraged leases. A leveraged lease is a lease in which the equity investor borrows money from a third-party lender to finance a portion of the purchase price of the asset involved and leases the asset to its ultimate user. In 1997 JH began investing in lease-in-lease-out (LILO) transactions and in 1999 began investing in…
1Opinion of the Court
JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.), AS SUCCESSOR IN INTEREST TO JOHN HANCOCK LIFE INSURANCE COMPANY (f.k.a. JOHN HANCOCK MUTUAL LIFE INSURANCE COMPANY) AND SUBSIDIARIES, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
John Hancock Life Ins. Co. (U.S.A.) v. Comm'r
Docket Nos. 6404-09, 7083-10, 7084-10
United States Tax Court
141 T.C. 1; 2013 U.S. Tax Ct. LEXIS 21; 141 T.C. No. 1;
August 5, 2013, Filed
Decisions will be entered pursuant to Rule 155.
JH is primarily in the business of selling life insurance policies, annuities, long-term care insurance, and other…
2Cases cited60 opinions
- Hertz Corp. v. FriendSupreme Court of the United States · 2010
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Knetsch v. United StatesSupreme Court of the United States · 1960
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