Reliance Ben. Asso. v. Commissioner
United States Tax Court
A reserve fund required by law to be computed upon the basis of the American Experience Table of Mortality, with 3 1/2 percent accretions, or which, if otherwise computed, must be substantially equivalent thereto, held to qualify as a true life insurance reserve maintained for the fulfillment of petitioner's combined life, health, and accident insurance contracts within the purview of section 201 (a) of the Revenue Acts of 1936 and 1938.
1Opinion of the Court
OPINION.
Arundell, Judge:
The Commissioner determined deficiencies in income tax for the years 1937 and 1938 in the respective amounts of $253.69 and $246.09. He held that petitioner was not a life insurance company because none of its reserve funds were held for the fulfillment of life insurance contracts within the meaning of section 201 of the Revenue Acts of 1936 and 1938 and the regulations promulgated thereunder. The facts are found as stipulated. Petitioner’s returns were filed in the district of Arizona.
Petitioner was incorporated in Arizona on March 11, 1937. On June 12. 1937. the…
2Cases cited2 opinions
- Pioneer Mutual Benefit Ass'n v. Corporation CommissionArizona Supreme Court · 1942
- General Life Ins. Co. v. CommissionerUnited States Tax Court · 1943
3Cited by5 opinions
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- Reliance Ben. Asso. v. CommissionerUnited States Tax Court · 1943