Standard Industrial L. Ins. Co. v. Commissioner
United States Board of Tax Appeals
Petitioner is a corporation organized under the statutes of Louisiana relating to industrial life insurance companies. Under the applicable state law it was required to maintain reserves computed on the basis of the American Experience Table of Mortality, with interest at 4 percent per annum. In neither of the taxable years did its reserves meet the required amounts.
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Petitioner is a corporation organized under the statutes of Louisiana relating to industrial life insurance companies. Under the applicable state law it was required to maintain reserves computed on the basis of the American Experience Table of Mortality, with interest at 4 percent per annum. In neither of the taxable years did its reserves meet the required amounts. Held, petitioner is not a life insurance company within the meaning of section 201 of the Revenue Act of 1936, even though the reserves which it maintained were approved by the insurance commissioner as adequate for purposes of…
1Opinion of the Court
*1012OPINION.
Arundell:
The issue before us is whether the insurance reserves maintained by the petitioner during the taxable years were adequate to bring petitioner within the definition of a life insurance company specified in sections 201 (a) and 203 (a) (2) of the Revenue Act of 1936 and articles 201 (a)-l and 203 (a) (2)-l of Regulations 94,1 *1013and thus to entitle it to report its net income under section 203 of that act. Section 201, as far as material here, provides that life insurance companies are those issuing life insurance contracts and whose reserve funds for the fulfillment of such…
2Cases cited5 opinions
- Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
- Helvering v. Illinois Life InsuranceSupreme Court of the United States · 1936
- McBride v. Acme Industrial Life Ins. Soc.Supreme Court of Louisiana · 1934
- Smith v. Unity Industrial Life Ins. Co.Louisiana Court of Appeal · 1938
- Williams v. Peoples Industrial Life Ins. Co. of LouisianaLouisiana Court of Appeal · 1939
3Cited by3 opinions
- Commissioner v. Swift & Co. Employes Ben. Ass'nCourt of Appeals for the Seventh Circuit · 1945
- Standard Industrial L. Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Swift & Co. Employees Ben. Asso. v. CommissionerUnited States Board of Tax Appeals · 1942