Legal Opinion

Phoenix Mut. Life Ins. Co. v. Commissioner

United States Tax Court

Decided March 26, 1991No. Docket No. 31993-87Published

P, a life insurance company, issued group term life insurance policies that provided extended life insurance coverage without further payment of premiums for employees who became totally disabled. P set aside a reserve for employees who had become disabled and eligible for the extended insurance.

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P, a life insurance company, issued group term life insurance policies that provided extended life insurance coverage without further payment of premiums for employees who became totally disabled. P set aside a reserve for employees who had become disabled and eligible for the extended insurance. Held: The reserve qualifies as a "life insurance reserve" under sec. 801(b). P utilized an annual premium assumption for its group term life insurance policies, resulting in the inclusion of net deferred and uncollected premiums in reserves, assets, and premium income. Held: The portion of P's…

1Opinion of the Court

Phoenix Mutual Life Insurance Co., Petitioner v. Commissioner of Internal Revenue, Respondent

Phoenix Mut. Life Ins. Co. v. Commissioner

Docket No. 31993-87

United States Tax Court

96 T.C. 497; 1991 U.S. Tax Ct. LEXIS 21; 96 T.C. No. 18;

March 26, 1991, Filed

Decision will be entered under Rule 155.

P, a life insurance company, issued group term life insurance policies that provided extended life insurance coverage without further payment of premiums for employees who became totally disabled. P set aside a reserve for employees who had become disabled and eligible for the extended insurance. Held:…

2Cases cited42 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
  3. New York v. MacLaySupreme Court of the United States · 1933
  4. Stark v. CommissionerUnited States Tax Court · 1986
  5. Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935

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