National Reserve Ins. Co. v. Commissioner
United States Tax Court
During 1939 and 1940 petitioner was engaged in writing life insurance contracts. Its mortality or reserve fund for the protection of its policyholders was maintained in compliance with its bylaws and insurance contracts and exceeded the reserves required by Arizona law. Petitioner erroneously charged on its books certain minor expense items to its mortality fund during each of the taxable years.
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During 1939 and 1940 petitioner was engaged in writing life insurance contracts. Its mortality or reserve fund for the protection of its policyholders was maintained in compliance with its bylaws and insurance contracts and exceeded the reserves required by Arizona law. Petitioner erroneously charged on its books certain minor expense items to its mortality fund during each of the taxable years. It charged refunds to policyholders and expenses incident to settlement of policy claims against the mortality fund as authorized by Arizona law. None of the charges so made impaired the reserves…
1Opinion of the Court
OPINION.
Arnold, Judge:
The question of whether a corporation operating under the Arizona Benefit Corporation Laws of 1937 is entitled to classification as a life insurance company for Federal income tax purposes was considered by this Court in Reliance Benefit Association, 2 T. C. 15; petition to review dismissed June 13, 1944, 143 Fed. (2d) 597. We there construed sections 201 (a) of the Revenue Acts of 1936 and 1938, the provisions of which are identical with the provisions of section 201 (a), Internal Revenue Code, set forth in the margin,1 and held the taxpayer was a life insurance company…
2Cases cited4 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Pioneer Mutual Benefit Ass'n v. Corporation CommissionArizona Supreme Court · 1942
- Reliance Ben. Asso. v. CommissionerUnited States Tax Court · 1943
3Cited by1 opinion
- National Reserve Ins. Co. v. CommissionerUnited States Tax Court · 1946