Western Nat'l Life Ins. Co. v. Commissioner
United States Tax Court
Under sec. 805(b)(4) of the 1954 Code, as amended by the Life Insurance Company Income Tax Act of 1959, the following items are includable or not includable in "assets" used in computing a life insurance company's taxable investment income (phase I): 1. That portion of the company's home office building, owned by it subject to a mortgage, not used by it for the conduct of its insurance business, is includable in "assets" at its fair market value unreduced by the mortgage…
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Under sec. 805(b)(4) of the 1954 Code, as amended by the Life Insurance Company Income Tax Act of 1959, the following items are includable or not includable in "assets" used in computing a life insurance company's taxable investment income (phase I): 1. That portion of the company's home office building, owned by it subject to a mortgage, not used by it for the conduct of its insurance business, is includable in "assets" at its fair market value unreduced by the mortgage indebtedness. 2. "Deferred and uncollected premiums," "due and unpaid premiums," and "loading" related thereto, are not…
1Opinion of the Court
Dkennen, Judge:
Respondent determined deficiencies in income tax against petitioner as follows:
Year Deficiency
1958 _$49,960.98
1959 _ 47,856.21
1960 _ 7,256. 03
1961_ 22,216.23
Respondent has conceded an issue relating to interest on policy and contract funds. Petitioner has conceded that it is not entitled to deduct from gross investment income in determining investment yield during the years in question, 80 percent of the interest paid on the mortgage, and that the respondent did not err in determining earnings rates pursuant to the provisions of section 805 (to), I.R.C. 1954, by increasing…
2Cases cited4 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Commissioner v. AckerSupreme Court of the United States · 1959
- Connecticut General, Life Ins. Co. v. EatonDistrict Court, D. Connecticut · 1914
3Cited by19 opinions
- Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
- Jefferson Standard Life Insurance Company v. United States of America, (Two Cases). Jefferson Standard Life Insurance Company v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1969
- Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
- Western and Southern Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
- Liberty National Life Insurance Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-Cross (Two Cases)Court of Appeals for the Fifth Circuit · 1972
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