Legal Opinion

United Fire Ins. Co. v. Commissioner

United States Tax Court

Decided September 19, 1983No. Docket No. 202-80Published

During the years in issue, petitioner, an insurance company, issued and reinsured accident and health insurance policies.

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During the years in issue, petitioner, an insurance company, issued and reinsured accident and health insurance policies. Most of the accident and health insurance policies issued or reinsured by petitioner contained a rider, clause, or provision which entitled the insured, at his option, to renew or continue the policy in force either for life or to a specified age of at least 60, at a level premium; i.e., the premium rate could not be adjusted due to the increased age or changed underwriting status of the insured. With respect to these level premium renewable accident and health policies,…

1Opinion of the Court

United Fire Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent

United Fire Ins. Co. v. Commissioner

Docket No. 202-80

United States Tax Court

81 T.C. 368; 1983 U.S. Tax Ct. LEXIS 39; 81 T.C. No. 26;

September 19, 1983, Filed

Decision will be entered under Rule 155.

During the years in issue, petitioner, an insurance company, issued and reinsured accident and health insurance policies. Most of the accident and health insurance policies issued or reinsured by petitioner contained a rider, clause, or provision which entitled the insured, at his option, to renew or continue…

Also in this document: Dissent.

2Cases cited27 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  3. Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
  4. Bogardus v. CommissionerSupreme Court of the United States · 1937
  5. Burnet v. GuggenheimSupreme Court of the United States · 1933

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