North American Life & Casualty Co. v. Commissioner
United States Tax Court
Petitioner, a life insurance company, had at the end of each taxable year amounts which represented deferred premiums on life insurance contracts. Held, petitioner is entitled to deduct commissions payable on the deferred premiums in determining gain from operations under sec. 809, I.R.C. 1954.
1Opinion of the Court
Wiles, Judge:
Respondent determined deficiencies in the income tax of petitioner for the years and in the amounts as follows:
Year Deficiency
1960 _ $3,053.38
1961_ 121,168.00
1963 _ 22,757.00
Some of the issues have been settled by the parties. The issues remaining for decision are:(1) Whether petitioner is entitled to deduct accrued commissions on deferred premiums in the year these premiums are included in income;(2) Alternatively, whether petitioner is entitled to deduct the loading portion of deferred premiums; or(3) Whether petitioner is entitled to exclude from income the loading portion of…
2Cases cited17 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
- 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
- Ohmer Register Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
12 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Western Casualty & Surety Co. v. CommissionerUnited States Tax Court · 1976
- Federal Life Insurance Company (Mutual) v. United StatesCourt of Appeals for the Seventh Circuit · 1975
- North Cent. Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- North American Life and Casualty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1976
- Midland Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1976
4 more not listed; retrieve them via the Exa API.