Western National Life Insurance Company of Texas v. Commissioner of Internal Revenue

TUTTLE, Circuit Judge:

In this appeal from the Tax Court of the United States the Commissioner of Internal Revenue challenges the correctness of the Tax Court’s determination of the method to be used in the computation of life insurance company taxable income under the Life Insurance Company Income Tax Act of 1959, Sections 801-820 of the Internal Revenue Code of 1954, as amended. The Tax Court held that the company could accrue “deferred and uncollected” annual premiums for the purpose of complying with state statute requirements that an amount equal to the policyholder’s share of the policy…