Farmers Life Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner created certain dividend funds under its policy contracts by putting aside $2 from each renewal premium. The funds were distributable pro rata to surviving, persistent policyholders after 21 years.
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1. Petitioner created certain dividend funds under its policy contracts by putting aside $2 from each renewal premium. The funds were distributable pro rata to surviving, persistent policyholders after 21 years. Held, such funds did not constitute reserves required by law so as to entitle petitioner to a 4 per cent reserve deduction. 2. Held, petitioner's coupon fund, guaranteeing definite credits upon premiums at a fixed future date, constituted a reserve required by law for which deduction is allowable under section 245(a)(2) of the Revenue Acts of 1924 and 1926. 3. In 1926 petitioner…
1Opinion of the Court
*426OPINION.
Maequette :
Five main questions are presented for decision by this proceeding. The first is whether petitioner’s guaranteed dividend fund, its survivorship fund, and its coupon fund constitute “ reserve funds required by law ” within the meaning of the Revenue Acts of 1924 and 1926. The provisions of those acts which are here pertinent are identical in wording and read as follows:
Sec. 245. (a) In the case of a life insurance company the term “ net income ” means the gross income less—
[[Image here]](2) An amount equal to the excess, if any, over the deduction specified in paragraph (1)…
2Cases cited6 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- New York Life Insurance v. EdwardsSupreme Court of the United States · 1926
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- United States v. Boston InsuranceSupreme Court of the United States · 1925
1 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Ellis Campbell, Jr., Director of Internal Revenue for the Second Collection District of Texas v. Great National Life Insurance CompanyCourt of Appeals for the Second Circuit · 1955
- Union Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1981
- Great Nat. Life Ins. v. CampbellDistrict Court, N.D. Texas · 1953
- Atlas Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
9 more not listed; retrieve them via the Exa API.