National States Ins. Co. v. Commissioner
United States Tax Court
Petitioner, an insurance company, issued guaranteed renewable health and accident insurance policies during the years in issue. Under these level premium policies, petitioner could neither cancel nor refuse to renew coverage for life or to age 65, but reserved the right to adjust the scale of premiums by class based on experience.
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Petitioner, an insurance company, issued guaranteed renewable health and accident insurance policies during the years in issue. Under these level premium policies, petitioner could neither cancel nor refuse to renew coverage for life or to age 65, but reserved the right to adjust the scale of premiums by class based on experience. Petitioner estimated its unearned premium reserve on the basis of gross pro rata unearned premiums and the additional reserve on the mid-terminal basis. The additional reserve, which reflected petitioner's long-term obligation stemming from the guaranteed renewable…
1DissentKorner, Judge
The issue presented for our decision in this case is whether petitioner’s accident and health policies which were in force 2 years or less, and with respect to which petitioner valued mid-terminal reserves on the 2-year preliminary term basis, qualified as "noncancellable” or "guaranteed renewable” accident and health policies for Federal tax purposes.
In resolving this issue, we are not provided with statutory guidance since the Internal Revenue Code nowhere defines the terms "noncancellable” or "guaranteed renewable” accident and health policies. Sections 1.801-3(c) and 1.801-3(d), Income…
2Cases cited26 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
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