Equitable Life Assurance Soc. v. Commissioner
United States Board of Tax Appeals
1. During the years 1933 and 1934 the petitioner, a mutual life insurance company, maintained the following reserves: (a) additional reserve on noncancellable accident and health policies; (b) Unpaid and unresisted accident and health claims; (c) Unearned accident and health premiums; (d) Total and permanent disability benefits, active lives; (e) Total and permanent disability, disabled lives; (f) Extra reserve for additional accidental death benefits.
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1. During the years 1933 and 1934 the petitioner, a mutual life insurance company, maintained the following reserves: (a) additional reserve on noncancellable accident and health policies; (b) Unpaid and unresisted accident and health claims; (c) Unearned accident and health premiums; (d) Total and permanent disability benefits, active lives; (e) Total and permanent disability, disabled lives; (f) Extra reserve for additional accidental death benefits. Held, that the above reserves constitute "reserve funds required by law" within the meaning of section 203(a)(2) of the Revenue Acts of 1932…
1Opinion of the Court
OPINION.
Smith:
These proceedings, consolidated for hearing, involve income tax deficiencies for 1933 and 1934 of $267,677.39 and $299,461.89, respectively. The respondent claims additional deficiencies for each of the taxable years.
The questions in issue are as follows:(1) Is the petitioner entitled to a reserve deduction for its “additional reserve on non-caneellable accident and health policies”? (The respondent in his answer, as amended, asserts that the allowance of this deduction for 1934 was in error.)(2) Is the petitioner entitled to a reserve deduction for a reserve called “unpaid and…
2Cases cited13 opinions
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Morrill v. JonesSupreme Court of the United States · 1883
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