Modern Life & Acci. Ins. Co. v. Commissioner
United States Tax Court
Petitioner is in the business of issuing cancelable and noncancelable accident and health insurance policies on the assessment plan in Illinois. Its members have a common equitable ownership of assets; its policyholders have the right to be members to the exclusion of others and to choose management; its sole business purpose is to supply insurance at cost to its members; and its members have a right to premiums in excess of amounts to cover losses and expenses.
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Petitioner is in the business of issuing cancelable and noncancelable accident and health insurance policies on the assessment plan in Illinois. Its members have a common equitable ownership of assets; its policyholders have the right to be members to the exclusion of others and to choose management; its sole business purpose is to supply insurance at cost to its members; and its members have a right to premiums in excess of amounts to cover losses and expenses. Held, that petitioner is taxable as a mutual insurance company under sec. 821, I.R.C. 1954, and not as an insurance company other…
1Opinion of the Court
Modern Life & Accident Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Modern Life & Acci. Ins. Co. v. Commissioner
Docket No. 3501-65
United States Tax Court
49 T.C. 670; 1968 U.S. Tax Ct. LEXIS 159;
March 25, 1968, Filed
Decision will be entered for the respondent.
Petitioner is in the business of issuing cancelable and noncancelable accident and health insurance policies on the assessment plan in Illinois. Its members have a common equitable ownership of assets; its policyholders have the right to be members to the exclusion of others and to choose management; its…
2Cases cited11 opinions
- Local Finance Corp. v. CommissionerUnited States Tax Court · 1967
- Theodore v. CommissionerUnited States Tax Court · 1962
- Order of R. Employees v. CommissionerUnited States Tax Court · 1943
- Holyoke Mut. Fire Ins. Co. v. CommissionerUnited States Tax Court · 1957
- Mutual Fire, Marine & Inland Ins. Co. v. CommissionerUnited States Tax Court · 1947
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