Pacific Mut. Life Ins. Co. v. Commissioner
United States Tax Court
Held: 1. Petitioner is not entitled to retroactively adjust its beginning 1958 group accident and health claim reserves and individual hospital and medical claim reserves for alleged overstatements therein. 2. Construction fees received by petitioner during the years 1958 through 1961 constituted investment income pursuant to sec. 804(b)(1)(B), I.R.C. 1954. 3. Option fee, standby fees, and bond commitment fees received by petitioner during the years 1959 through 1961 were…
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Held: 1. Petitioner is not entitled to retroactively adjust its beginning 1958 group accident and health claim reserves and individual hospital and medical claim reserves for alleged overstatements therein. 2. Construction fees received by petitioner during the years 1958 through 1961 constituted investment income pursuant to sec. 804(b)(1)(B), I.R.C. 1954. 3. Option fee, standby fees, and bond commitment fees received by petitioner during the years 1959 through 1961 were improperly included in petitioner's computation of gain from operations pursuant to sec. 809(c)(3), I.R.C. 1954, and are…
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in petitioner’s income tax for the years and in the amounts as follows:
Year Amount
1958 _$149,679.43
1959 _1_ 54,882.51
1960 _ 55,324 93
1961_ 58,772.85
The issues for determination are as follows:(1) Whether petitioner may retroactively adjust its 'beginning 1958 group accident and health claim reserves and individual hospital and medical claim reserves for 'alleged overstatements therein.(2) Whether the construction fees received by petitioner during the years 1958 through 1961 were reportable as gain from operations pursuant to section 809…
2Cases cited3 opinions
- Malat v. RiddellSupreme Court of the United States · 1966
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Clay v. CommissionerUnited States Tax Court · 1966
3Cited by14 opinions
- Group Life and Health Insurance Company v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1981
- Home Mutual Insurance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Seventh Circuit · 1980
- Commissioner of Internal Revenue v. Pacific Mutual Life Insurance CompanyCourt of Appeals for the Ninth Circuit · 1969
- Home Mut. Ins. Co. v. CommissionerUnited States Tax Court · 1978
- Massachusetts Mutual Life Insurance v. United StatesUnited States Court of Claims · 1984
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