Bankers Union Life Ins. Co. v. Commissioner
United States Tax Court
1. Held: 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 (phase I), and in "gross amount of premiums" under sec. 809(c), I.R.C. 1954, for purposes of computing the tax on petitioner's gain from operations (phase II) under the Life Insurance Company Income Tax Act of 1959. Four Courts of Appeals decisions followed.
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1. Held: 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 (phase I), and in "gross amount of premiums" under sec. 809(c), I.R.C. 1954, for purposes of computing the tax on petitioner's gain from operations (phase II) under the Life Insurance Company Income Tax Act of 1959. Four Courts of Appeals decisions followed. Decisions of this Court in Western National Life Insurance Co. of Texas, 50 T.C. 285 (1968), modified 51 T.C. 824 (1969), revd. 432 F. 2d 298 (C.A.…
1Opinion of the Court
Bankers Union Life Insurance Co., Petitioner v. Commissioner of Internal Revenue, Respondent
Bankers Union Life Ins. Co. v. Commissioner
Docket Nos. 5807-71, 442-73
United States Tax Court
62 T.C. 661; 1974 U.S. Tax Ct. LEXIS 58; 62 T.C. No. 74;
August 21, 1974, Filed
Decisions will be entered under Rule 155.
1. Held: 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 (phase I), and in "gross amount of premiums" under sec. 809(c), I.R.C. 1954, for purposes of computing…
Also in this document: Concurrence.
2Cases cited35 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Woodward v. CommissionerSupreme Court of the United States · 1970
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