Time Ins. Co. v. Commissioner
United States Tax Court
Held, computations of reserves for medical insurance claims in accordance with NAIC rules not inconsistent with accrual method of accounting because such computations not recognized in accrual accounting. Held, further, NAIC rules are applicable to such computations since Code and Regulations are silent on matter. Commissioner v. Standard Life & Accident Insurance Co., 433 U.S. 148 (1977).
1Opinion of the Court
SHIELDS, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Year Deficiency
1972 . $1,935,682.54
1973 . 397,760.23
1974 . 193,267.27
1975 . 483,091.21
After a number of concessions, the issues remaining are: (1) Whether petitioner properly computed its claim reserves on certain accident and health policies during the years in. issue; (2) whether respondent’s disallowance of a portion of petitioner’s deductions for claim reserves was so arbitrary and unreasonable as to shift the burden of going forward with the evidence with respect to the correct amount of the…
2Cases cited18 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Roberts v. CommissionerUnited States Tax Court · 1974
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Nor-Cal Adjusters, AKA Nor-Cal Insurance Adjusters, Formerly Hobson Adjusters, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
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