Inter-American Life Ins. Co. v. Commissioner
United States Tax Court
Petitioner was incorporated in Arizona as a limited stock life insurance company in July 1957 and received its certificate of authority to transact life insurance business in Arizona on Dec. 30, 1957. From the latter date and continuing through its taxable year 1961, petitioner, although its sole active business was in life insurance, did not aggressively engage in the life insurance business and at the end of 1961, petitioner considered temporary surrender of its…
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Petitioner was incorporated in Arizona as a limited stock life insurance company in July 1957 and received its certificate of authority to transact life insurance business in Arizona on Dec. 30, 1957. From the latter date and continuing through its taxable year 1961, petitioner, although its sole active business was in life insurance, did not aggressively engage in the life insurance business and at the end of 1961, petitioner considered temporary surrender of its certificate of authority to transact insurance business. During each of the years 1958 through 1961, petitioner's investment…
1Opinion of the Court
"WitheYj Judge:
The Commissioner has determined deficiencies in petitioner’s income taxes and assessed additions to tax thereon in the amounts and for the taxable years shown below:
Taxable year ended Deficiency Addition to tax Sec. 6651(a) Sec. 6G53(a
1958_ $8, 372. 69 $2, 007. 30 $421. 47
1959_ 7, 684. 22 1, 921. 06 429. 08
1960_ 864. 37 206. 85 51. 37
1961_ 17, 780. 17 3, 561. 97 889. 01
Due to certain concessions, the primary issues to be decided are: (1) Whether during any or all of the years in issue, petitioner qualified as a life insurance company under section 801(a) j1 (2) whether ceitain…
2Cases cited1 opinion
- Cardinal Life Insurance v. United StatesDistrict Court, N.D. Texas · 1969
3Cited by46 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Estate of Mason v. CommissionerUnited States Tax Court · 1975
- Waddell v. CommissionerUnited States Tax Court · 1986
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Magnon v. CommissionerUnited States Tax Court · 1980
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