Consumer Life Insurance v. United States

This is a single issue tax refund suit that arises out of a small loan company’s entry into the insurance business through a wholly owned subsidiary that is formed especially for that purpose. The question is whether that subsidiary, the plaintiff in this proceeding, qualified for the tax treatment accorded a “life insurance company” by §§ 801 et seq. of the Internal Bevenue Code of 1954. We hold for the plaintiff.

This case is before this court on a review of a recommended decision of Trial Judge George Willi. The court disagrees with the conclusions. A similar case, Penn Security Life…