Carnation Co. v. Commissioner
United States Tax Court
Petitioner and an unrelated insurance company entered into an "insurance" agreement. Simultaneously, the unrelated insurance company "reinsured" 90 percent of its risk under that agreement with petitioner's wholly owned Bermudan subsidiary. However, before the unrelated insurance company would participate in the "reinsurance" agreement, petitioner had to give its wholly owned Bermudan subsidiary access upon demand to an additional $ 2,880,000 in capital contributions.
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Petitioner and an unrelated insurance company entered into an "insurance" agreement. Simultaneously, the unrelated insurance company "reinsured" 90 percent of its risk under that agreement with petitioner's wholly owned Bermudan subsidiary. However, before the unrelated insurance company would participate in the "reinsurance" agreement, petitioner had to give its wholly owned Bermudan subsidiary access upon demand to an additional $ 2,880,000 in capital contributions. Without regard to the demand agreement, petitioner's capital contribution to its wholly owned Bermudan subsidiary was $…
1Opinion of the Court
Carnation Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Carnation Co. v. Commissioner
Docket No. 5793-76
United States Tax Court
71 T.C. 400; 1978 U.S. Tax Ct. LEXIS 7;
December 26, 1978, Filed
Petitioner and an unrelated insurance company entered into an "insurance" agreement. Simultaneously, the unrelated insurance company "reinsured" 90 percent of its risk under that agreement with petitioner's wholly owned Bermudan subsidiary. However, before the unrelated insurance company would participate in the "reinsurance" agreement, petitioner had to give its wholly owned Bermudan…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Securities & Exchange Commission v. Variable Annuity Life InsuranceSupreme Court of the United States · 1959
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
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