Modern American Life Ins. Co. v. Commissioner
United States Tax Court
M & P guaranteed payments to certain of their policyholders in 1978 and 1979. Held, the payments are properly characterized as policyholder dividends under sec. 809(d)(3) of the Internal Revenue Code. Held, further, the reserves established for the payment of these guaranteed payments are policyholder dividend reserves.
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M & P guaranteed payments to certain of their policyholders in 1978 and 1979. Held, the payments are properly characterized as policyholder dividends under sec. 809(d)(3) of the Internal Revenue Code. Held, further, the reserves established for the payment of these guaranteed payments are policyholder dividend reserves. Held, further, M is entitled to an operations loss carryback under sec. 812 of the Internal Revenue Code, to 1978 and 1979 based upon a total operations loss of $ 1,418,441 in 1981.
1Opinion of the Court
Modern American Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent; Modern American Life Insurance Company, a Missouri Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Modern American Life Ins. Co. v. Commissioner
Docket Nos. 17025-85, 31081-85
United States Tax Court
92 T.C. 1230; 1989 U.S. Tax Ct. LEXIS 84; 92 T.C. No. 80;
June 8, 1989. June 8, 1989, Filed
Decisions will be entered under Rule 155.
M & P guaranteed payments to certain of their policyholders in 1978 and 1979. Held, the payments are properly characterized as policyholder…
2Cases cited9 opinions
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- American National Insurance v. United StatesUnited States Court of Claims · 1982
- Prairie States Life Insurance Co. v. United StatesCourt of Appeals for the Eighth Circuit · 1987
- Republic National Life Insurance Company, Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
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