American Cent. Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. An "insured's personal benefit fund" consisting of contributions by policyholders with fixed interest contributed by the insurance company, the fund to be distributed among the surviving persistent policyholders as provided by the insurance policy, sanctioned and required by state law and regulation, held a "reserve required by law" under the revenue acts. 2. Premium reduction coupon policy reserves held reserves required by law. 3. The statutory rental value of space…
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1. An "insured's personal benefit fund" consisting of contributions by policyholders with fixed interest contributed by the insurance company, the fund to be distributed among the surviving persistent policyholders as provided by the insurance policy, sanctioned and required by state law and regulation, held a "reserve required by law" under the revenue acts. 2. Premium reduction coupon policy reserves held reserves required by law. 3. The statutory rental value of space occupied by an insurance company in its own building must be included in gross income as a condition to the deduction of…
1Opinion of the Court
*1187OPINION.
Steknhagen:
1. In computing the deduction under section 245, Bevenue Act of 1926, and section 203, Bevenue Act of 1928, the Commissioner has excluded from the “ reserve funds required by law ” the stipulated amounts of the insured’s personal benefit fund. This fund, as is shown by the findings, consists of amounts of $6.23 each contributed by policyholders as provided in the policies called “ Whole Life Premium Seduction Payable at Death.” This fund is by the terms of the policy built up for a period of 19 years, when, with the accretion of the company’s fixed interest contributions,…
2Cases cited11 opinions
- Helvering v. Independent Life InsuranceSupreme Court of the United States · 1934
- 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
- John Hancock Mut. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
6 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- American Cent. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- GREAT SOUTHERN LIFE INS. CO. v. COMMISSIONERUnited States Board of Tax Appeals · 1935