Old Line Ins. Co. v. Commissioner
United States Board of Tax Appeals
A contingency reserve for anticipated excessive mortality losses and possible losses in reserves invested, which was maintained by petitioner in addition to a reserve of the net value of outstanding policies is not a reserve required by law within the meaning of section 245(a)(2) of the Revenue Act of 1921.
1Opinion of the Court
*759OPINION.
Lansdon:
Section 245(a) (1) and (2) of the Revenue Act of 192J provides:
That in the case of a life insurance company the term “ net income ” means the gross income less—(1) The amount of interest received during the taxable year which under paragraph (4) of subdivision (b) of section 213 is exempt from taxation under this title;(2) An amount equal to the excess, if any, over the deduction specified in paragraph (1) of this subdivision, of 4 per centum of the mean of the reserve funds required by law and held at the beginning and end of the taxable year, plus (in case of life insurance…
2Cases cited7 opinions
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- United States v. Boston InsuranceSupreme Court of the United States · 1925
- Jefferson v. New York Life InsuranceCourt of Appeals of Kentucky · 1913
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- American Cent. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Kaskaskia Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Midland Nat'l Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- North American Reassurance Co. v. CommissionerUnited States Board of Tax Appeals · 1934
1 more not listed; retrieve them via the Exa API.