General Life Ins. Co. v. Commissioner
United States Tax Court
1. Its "reserves" failing to qualify as true life insurance reserves, petitioner, held, not a life insurance company within the applicable law. 2. Premiums received by petitioner in ordinary course, although partly dedicated to the payment of claims under its policy contracts, held, income to it.
1Opinion of the Court
OPINION.
OppeR, Judge:
Under the rule which we have consistently followed, petitioner is not a life insurance company within the definition of section 201 of the Internal Revenue Code1 unless at least 50 percent of “its total reserve funds” are true life insurance reserves required to be maintained by the law under which it operates. Standard Industrial Life Insurance Co. of Louisiana, Inc.., 42 B. T. A. 1011; Independent Life & Accident Insurance Co., 47 B. T. A. 894; see also Swift & Co. Employes Benefit Association, 47 B. T. A. 1011. Petitioner, which does business on the mutual assessment…
2Cases cited2 opinions
- Penn Mutual Life Insurance v. LedererSupreme Court of the United States · 1920
- Clay Sewer Pipe Asso. v. CommissionerUnited States Tax Court · 1943
3Cited by5 opinions
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- Order of R. Employees v. CommissionerUnited States Tax Court · 1943