Midland Nat'l Life Ins. Co. v. Commissioner
United States Tax Court
Under the Life Insurance Company Income Tax Act of 1959, it is held: 1. Deferred and uncollected premiums, including loading, are includable in "assets" under sec. 805(b)(4), I.R.C. 1954, for purposes of computing the tax on petitioner's investment income (phases I and II). 2. Deferred and uncollected premiums are includable in "gross amount of premiums" under sec. 809(c)(1), I.R.C. 1954, for purposes of computing the tax on petitioner's gain or loss from operations (phase…
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Under the Life Insurance Company Income Tax Act of 1959, it is held: 1. Deferred and uncollected premiums, including loading, are includable in "assets" under sec. 805(b)(4), I.R.C. 1954, for purposes of computing the tax on petitioner's investment income (phases I and II). 2. Deferred and uncollected premiums are includable in "gross amount of premiums" under sec. 809(c)(1), I.R.C. 1954, for purposes of computing the tax on petitioner's gain or loss from operations (phase II). 3. Petitioner is not entitled to a deduction under sec. 809(d)(12), I.R.C. 1954, for the increase in loading and…
1Opinion of the Court
Midland National Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Midland Nat'l Life Ins. Co. v. Commissioner
Docket Nos. 5939-73, 10081-74
United States Tax Court
66 T.C. 550; 1976 U.S. Tax Ct. LEXIS 86;
June 22, 1976, Filed
Decisions will be entered under Rule 155.
Under the Life Insurance Company Income Tax Act of 1959, it is held:
1. Deferred and uncollected premiums, including loading, are includable in "assets" under sec. 805(b)(4), I.R.C. 1954, for purposes of computing the tax on petitioner's investment income (phases I and II).
2. Deferred and uncollected…
2Cases cited13 opinions
- Jefferson Standard Life Insurance Company v. United States of America, (Two Cases). Jefferson Standard Life Insurance Company v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1969
- The Franklin Life Insurance Company v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
- Western National Life Insurance Company of Texas v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Western and Southern Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
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