Legal Opinion

Opn. No.

New York Attorney General Reports

Decided February 6, 1976Published

1Opinion of the Court

HON. JAMES H. TULLY, JR. Commissioner of Taxation and Finance

This is in reply to your request for my opinion concerning the application of Tax Law, Section 1510(b)(1) to a new form of group accident and health insurance proposed by the Equitable Life Assurance Society of the United States.

Specifically, you ask whether the amounts received by the Equitable Life Assurance Society of the United States from the contract holders, under a contract pursuant to which the insurance company would guarantee benefit payments to covered employees and then be fully reimbursed by the employer, constitute…

2Cases cited3 opinions

  1. MATTER OF GUARDIAN LIFE INS. CO. v. ChapmanNew York Court of Appeals · 1951
  2. Mutual Life Insurance v. New York State Tax CommissionNew York Court of Appeals · 1973
  3. Inter-County Title Guaranty & Mortgage Co. v. State Tax CommissionNew York Court of Appeals · 1971

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