Legal Opinion

USAA Life Ins. Co.

United States Tax Court

Decided January 14, 1993No. Docket No. 18187-88Unpublished

P, an insurance company, was required to maintain a minimum reserve for its universal life insurance policies equal to the cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the State, two separate reserve amounts (8A and 8G reserves) that together equaled the cash surrender value of the policies.

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P, an insurance company, was required to maintain a minimum reserve for its universal life insurance policies equal to the cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the State, two separate reserve amounts (8A and 8G reserves) that together equaled the cash surrender value of the policies. The 8A reserve, a life insurance reserve as defined in sec. 801(b), I.R.C., was computed under a preliminary term method and was subject to the revaluation provisions of sec. 818(c), I.R.C. Held, the 8G reserve represents an amount…

1Opinion of the Court

USAA LIFE INSURANCE COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent

USAA Life Ins. Co.

Docket No. 18187-88

United States Tax Court

T.C. Memo 1993-18; 1993 Tax Ct. Memo LEXIS 18; 65 T.C.M. (CCH) 1756;

January 14, 1993, Filed

Decision will be entered under Rule 155.

P, an insurance company, was required to maintain a minimum reserve for its universal life insurance policies equal to the cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the State, two separate reserve amounts (8A and 8G reserves) that together…

2Cases cited3 opinions

  1. Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
  2. USAA Life Ins. Co. v. CommissionerUnited States Tax Court · 1990
  3. Usaa Life Ins. v. c.i.r.usaa Life Ins. v. CCourt of Appeals for the Fifth Circuit · 1991

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