Anchor Nat'l Life Ins. Co. v. Commissioner
United States Tax Court
P, a stock life insurance company, was required by the California Insurance Department to increase its reserves for certain policies. P filed suit in California to challenge that action. Prior to a decision in the suit, P believed it needed to maintain additional reserves up to the level required by the California Insurance Department so it would not have the appearance of insolvency in its annual statements.
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P, a stock life insurance company, was required by the California Insurance Department to increase its reserves for certain policies. P filed suit in California to challenge that action. Prior to a decision in the suit, P believed it needed to maintain additional reserves up to the level required by the California Insurance Department so it would not have the appearance of insolvency in its annual statements. W Corp., P's parent corporation, provided the funds necessary for P to maintain the reserves required by the California Insurance Department and P, in return, issued certificates of…
1Opinion of the Court
PARKER, Judge:
Respondent determined a deficiency of $4,160,820 for the taxable year 1979 and $3,227,095 for the taxable year 1980. The issues for decision1 are:(1) Whether the amounts payable by petitioner on certificates of contribution that it issued to its parent corporation are deductible as interest; -■(2) Whether petitioner may reduce its gross premium income by the amount of its anticipated cost of collection in excess of loading on its deferred and uncollected premiums (unpaid premiums);(3) Whether petitioner must include deficiency reserves as additional premium income when these…
2Cases cited44 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- United States v. DavisSupreme Court of the United States · 1962
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
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3Cited by23 opinions
- Calumet Industries, Inc. v. CommissionerUnited States Tax Court · 1990
- Nestle Holdings v. CommissionerUnited States Tax Court · 1995
- CMA Consol., Inc. v. Comm'rUnited States Tax Court · 2005
- Harco Holdings, Incorporated, and Subsidiaries v. United StatesCourt of Appeals for the Seventh Circuit · 1992
- Rutter v. Comm'rUnited States Tax Court · 2017
18 more not listed; retrieve them via the Exa API.