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