Mutual Ben. Life Ins. Co. v. Commissioner
United States Tax Court
A reserve to fund the additional cost of providing annuities to the beneficiaries under its life insurance policies, expressly authorized by State statute, which became subject to the regulatory authority of the State commission, qualified as a life insurance reserve within the meaning of sec. 801(b).
1Opinion of the Court
Quealy, Judge:
The.respondent, determined deficiencies in petitioner’s income taxes as follows:
Year Deficiency
1958 _$295, 077.97
1969 _ 296,495.14
1960 _ 296,297.16
The sole question involved is whether an additional reserve established by the petitioner to supplement the basic policy reserve in meeting its obligations under the optional mode of settlement contract embodied in certain of its policies qualified during the years 1958, 1959, and 1960 as a life insurance reserve as defined in section 801(b).1
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits…
2Cases cited2 opinions
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
- Lamana-Panno-Fallo Industrial Ins. v. CommissionerCourt of Appeals for the Fifth Circuit · 1942
3Cited by16 opinions
- Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- The Mutual Benefit Life Insurance Company, (James P. Moore, Jr., Vice President and Comptroller) v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1974
- Lincoln National Life Insurance v. United StatesUnited States Court of Claims · 1978
- DELTA LIFE INSURANCE COMPANY v. United StatesDistrict Court, E.D. Louisiana · 1973
- USAA Life Ins. Co. v. CommissionerUnited States Tax Court · 1990
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