Missouri State Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. DEDUCTIONS - LIFE INSURANCE COMPANIES - RESERVES. - Petitioner's reserve set up to meet its liability upon matured coupons under its "guaranteed premium reduction coupon policies" held to represent a legal reserve for computation of its deduction under section 203(a)(2) of the Revenue Act of 1928. 2. Id. - INTEREST. - Amounts paid as interest by petitioner upon deferred dividends under policies whose tontine period ended in the year of such payment held to represent…
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1. DEDUCTIONS - LIFE INSURANCE COMPANIES - RESERVES. - Petitioner's reserve set up to meet its liability upon matured coupons under its "guaranteed premium reduction coupon policies" held to represent a legal reserve for computation of its deduction under section 203(a)(2) of the Revenue Act of 1928. 2. Id. - INTEREST. - Amounts paid as interest by petitioner upon deferred dividends under policies whose tontine period ended in the year of such payment held to represent additional dividends and not interest subject to deduction. Lafayette Life Ins. Co.,26 B.T.A. 946, followed. 3. Id. -…
1Opinion of the Court
OPINION.
Leech :
Petitioner, a Missonri corporation, carrying on a life insurance business, with its home office at St. Louis, Missouri, by these proceedings consolidated for hearing and decision, seeks redetermination of deficiencies of $4,388.52 and $66,794.13, determined by respondent for the calendar years 1928 and 1929, respectively. The same eight issues are presented by each petition for each year. Respondent raises additional issues by amended answers, charging that he, in error, (a) allowed deductions in each of the taxable years of amounts representing taxes paid in those years upon…
2Cases cited23 opinions
- Taft v. BowersSupreme Court of the United States · 1929
- New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- United States v. Boston InsuranceSupreme Court of the United States · 1925
- H. H. Brown Co. v. CommissionerUnited States Board of Tax Appeals · 1927
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3Cited by14 opinions
- Descartes v. Tribunal de Contribuciones de Puerto RicoSupreme Court of Puerto Rico · 1950
- Penn Mut. Life Ins. Co. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1937
- Illinois Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Harwell v. CommissionerCourt of Appeals for the Tenth Circuit · 1948
- Atlas Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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