Modern Home Life Ins. Co. v. Commissioner
United States Tax Court
Held, an insurance company, which undertakes to pay the monthly sum due on the insured's mortgage while the insured is absent from work on account of illness or other disability, may treat as "unpaid losses" within the meaning of sec. 832(b)(5), the estimated liability in a subsequent year on account of a disabling illness or accidental injury in the taxable year (sec. 832(b)(5); Regs. sec. 1.832-1).
1Opinion of the Court
OPINION
The petitioner claims, and the respondent concedes, that the petitioner is taxable as an insurance company (other than life or mutual) under part III (secs. 831 and 832) 5 of subchapter L. Section 832 (c) (4) permits an insurance company to deduct losses incurred (as defined in subsection (b) (5) of section 832) during the taxable year. Section 832(b) (5) provides as follows:(b) Definitions. — In the case of an insurance company subject to the tax imposed, by section 831—
* * ⅜ * * *(5) Losses incueeed. — The term “losses incurred” means losses incurred during the taxable year on…
2Cases cited6 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Peoples Bank & Trust Co. v. CommissionerUnited States Tax Court · 1968
- Peoples Bank and Trust Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1969
- Pacific Employers Ins. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1937
- Pacific Employers Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1935
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Maryland Deposit Ins. Fund Corp. v. CommissionerUnited States Tax Court · 1987
- Supermarkets General Corp. v. United StatesDistrict Court, D. New Jersey · 1982
- Maryland Deposit Ins. Fund Corp. v. CommissionerUnited States Tax Court · 1987
- Modern Home Life Ins. Co. v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.