Legal Opinion

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

United States Tax Court

Decided September 28, 1989No. Docket No. 40452-84Published

P, a stock life insurance company, was required by the California Insurance Department to increase its reserves for certain policies. P filed suit in California to challenge that action. Prior to a decision in the suit, P believed it needed to maintain additional reserves up to the level required by the California Insurance Department so it would not have the appearance of insolvency in its annual statements.

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P, a stock life insurance company, was required by the California Insurance Department to increase its reserves for certain policies. P filed suit in California to challenge that action. Prior to a decision in the suit, P believed it needed to maintain additional reserves up to the level required by the California Insurance Department so it would not have the appearance of insolvency in its annual statements. W Corp., P's parent corporation, provided the funds necessary for P to maintain the reserves required by the California Insurance Department and P, in return, issued certificates of…

1Opinion of the Court

Anchor National Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent

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

Docket No. 40452-84

United States Tax Court

93 T.C. 382; 1989 U.S. Tax Ct. LEXIS 130; 93 T.C. No. 34;

September 28, 1989September 28, 1989, Filed

Decision will be entered under Rule 155.

P, a stock life insurance company, was required by the California Insurance Department to increase its reserves for certain policies. P filed suit in California to challenge that action. Prior to a decision in the suit, P believed it needed to maintain additional reserves up…

2Cases cited45 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
  3. United States v. DavisSupreme Court of the United States · 1962
  4. Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
  5. Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972

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