Legal Opinion

Western Nat'l Life Ins. Co. v. Commissioner

United States Tax Court

Decided February 24, 1969No. Docket No. 1621-64PublishedCited by 18 opinions

Upon reconsideration, held: That net "deferred and uncollected premiums" and net "due and unpaid premiums" (exclusive of loading) are includable in assets for computing taxpayer's share of investment income under sec. 804, I.R.C. 1954, as amended. Original opinion of this Court filed May 13, 1968, reported in 50 T.C. 285, modified accordingly; affirmed on all other issues.

1Opinion of the Court

SUPPLEMENTAL OPINION

Drennen, Judge:

Respondent filed a timely motion for reconsideration and revision of the original opinion filed by this Court in this proceeding on May 13, 1968, reported in 50 T.C. at 285.1 The motion was that the Court “modify said opinion by deciding the gross deferred and uncollected and gross due and unpaid premium asset issues (issues Nos. 2, 3, and 4 in the Opinion) in accord with the contention of the respondent.” Respondent’s motion was set down for oral argument on August 7,1968, and the Court invited counsel2 for the American Life Convention and the Life…

2Cases cited2 opinions

  1. The Franklin Life Insurance Company v. United StatesCourt of Appeals for the Seventh Circuit · 1968
  2. Jefferson Standard Life Insurance Co. v. United StatesDistrict Court, M.D. North Carolina · 1967

3Cited by18 opinions

  1. Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
  2. Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
  3. Western and Southern Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
  4. Liberty National Life Insurance Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-Cross (Two Cases)Court of Appeals for the Fifth Circuit · 1972
  5. Great Commonwealth Life Insurance Co. v. United StatesCourt of Appeals for the Fifth Circuit · 1974

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