Legal Opinion

Pan-American Life Ins. Co. v. Commissioner (A)

United States Board of Tax Appeals

Decided December 23, 1938No. Docket No. 84638Published

1. Where petitioner, a life insurance company, issued policies of combined life, health, and accident insurance, and some of the policies contained premium waiver benefits in case of total and permanent disability, and others contained both premium waiver benefits and monthly income benefits in case of total and permanent disability, it is held, that a reserve for incurred but not yet accrued disability benefits embracing both premium waiver and monthly income benefits held…

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1. Where petitioner, a life insurance company, issued policies of combined life, health, and accident insurance, and some of the policies contained premium waiver benefits in case of total and permanent disability, and others contained both premium waiver benefits and monthly income benefits in case of total and permanent disability, it is held, that a reserve for incurred but not yet accrued disability benefits embracing both premium waiver and monthly income benefits held by petitioner at the beginning and end of the taxable year comes within the term "reserve funds required by law" as that…

1Opinion of the Court

PAN-AMERICAN LIFE INSURANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Pan-American Life Ins. Co. v. Commissioner (A)

Docket No. 84638.

United States Board of Tax Appeals

38 B.T.A. 1430; 1938 BTA LEXIS 740;

December 23, 1938, Promulgated

1. Where petitioner, a life insurance company, issued policies of combined life, health, and accident insurance, and some of the policies contained premium waiver benefits in case of total and permanent disability, and others contained both premium waiver benefits and monthly income benefits in case of total and permanent disability, it…

2Cases cited15 opinions

  1. Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
  2. Massachusetts Mutual Life Insurance v. United StatesSupreme Court of the United States · 1933
  3. New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
  4. Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
  5. McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917

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