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
SUPPLEMENTAL FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the year ended December 31, 1980, in the amount of $6,223,612. The issues we Consider in this supplemental opinion1 are: (1) Whether a reserve set aside by petitioner for insureds who were eligible, under group term life insurance policies, for extended insurance coverage without further payment of premiums by reason of their disability, qualifies as a “life insurance reserve” under section 801(b),2 (2) whether, in the context of group term life insurance policies,…
2Cases cited41 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
36 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Phoenix Mut. Life Ins. Co. v. CommissionerUnited States Tax Court · 1991