Legal Opinion

Equitable Life Assurance Soc. v. Commissioner

United States Board of Tax Appeals

Decided April 29, 1941No. Docket Nos. 89294, 93805Published

1. During the years 1933 and 1934 the petitioner, a mutual life insurance company, maintained the following reserves: (a) additional reserve on noncancellable accident and health policies; (b) Unpaid and unresisted accident and health claims; (c) Unearned accident and health premiums; (d) Total and permanent disability benefits, active lives; (e) Total and permanent disability, disabled lives; (f) Extra reserve for additional accidental death benefits.

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1. During the years 1933 and 1934 the petitioner, a mutual life insurance company, maintained the following reserves: (a) additional reserve on noncancellable accident and health policies; (b) Unpaid and unresisted accident and health claims; (c) Unearned accident and health premiums; (d) Total and permanent disability benefits, active lives; (e) Total and permanent disability, disabled lives; (f) Extra reserve for additional accidental death benefits. Held, that the above reserves constitute "reserve funds required by law" within the meaning of section 203(a)(2) of the Revenue Acts of 1932…

1Opinion of the Court

THE EQUITABLE LIFE ASSURANCE SOCIETY OF THE UNITED STATES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Equitable Life Assurance Soc. v. Commissioner

Docket Nos. 89294, 93805.

United States Board of Tax Appeals

44 B.T.A. 293; 1941 BTA LEXIS 1342;

April 29, 1941, Promulgated

1. During the years 1933 and 1934 the petitioner, a mutual life insurance company, maintained the following reserves: (a) additional reserve on noncancellable accident and health policies; (b) Unpaid and unresisted accident and health claims; (c) Unearned accident and health premiums; (d) Total and permanent…

2Cases cited23 opinions

  1. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  2. Morrill v. JonesSupreme Court of the United States · 1883
  3. Edwards v. DouglasSupreme Court of the United States · 1925
  4. New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
  5. Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935

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