USAA Life Ins. Co. v. Commissioner
United States Tax Court
State regulatory authorities required P to maintain a minimum reserve for its universal life insurance policies equal to the total cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the States, two separate reserve amounts that together equaled the total cash surrender value. The annual statement represented one reserve amount as a preliminary term reserve and the other as an excess miscellaneous reserve.
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State regulatory authorities required P to maintain a minimum reserve for its universal life insurance policies equal to the total cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the States, two separate reserve amounts that together equaled the total cash surrender value. The annual statement represented one reserve amount as a preliminary term reserve and the other as an excess miscellaneous reserve. P contends that the purported preliminary term reserve was subject to the revaluation provisions of sec. 818(c), I.R.C.…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax in the amounts of $391,571.79 for 1982 and $2,225,593.60 for 1983. After concessions by petitioner, the principal issue for decision is (1) whether petitioner for 1983 was entitled to revalue, under section 818(c),1 certain of the reserves that corresponded to its universal life insurance policies. If petitioner was so entitled, the issue then becomes (2) whether petitioner’s computations relating to the revaluation were correct. If petitioner’s computations were incorrect, the issues become (3) whether…
2Cases cited29 opinions
- United States v. PriceSupreme Court of the United States · 1960
- Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- United States v. Consumer Life Insurance Co.Supreme Court of the United States · 1977
- Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
24 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Phoenix Mut. Life Ins. Co. v. CommissionerUnited States Tax Court · 1991
- Phoenix Mut. Life Ins. Co. v. CommissionerUnited States Tax Court · 1991
- USAA Life Ins. Co.United States Tax Court · 1993
- USAA Life Ins. Co. v. CommissionerUnited States Tax Court · 1990
- Western Southern Life Insurance v. United StatesDistrict Court, S.D. Ohio · 1993