National Sav. Life Ins. Co. v. Commissioner
United States Tax Court
Petitioner, a life insurance company under subch. L, I.R.C. 1954, acquired life insurance reserves from Progressive, also a life insurance company under subch. L, I.R.C. 1954, pursuant to a statutory merger. Petitioner had elected under sec. 818(c), I.R.C. 1954, to revalue its preliminary term reserves, while Progressive had not so elected.
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Petitioner, a life insurance company under subch. L, I.R.C. 1954, acquired life insurance reserves from Progressive, also a life insurance company under subch. L, I.R.C. 1954, pursuant to a statutory merger. Petitioner had elected under sec. 818(c), I.R.C. 1954, to revalue its preliminary term reserves, while Progressive had not so elected. Held, sec. 381, I.R.C. 1954, does not require petitioner to add the acquired reserves to its sec. 810, I.R.C. 1954, opening balance in the revalued amount; rather, petitioner must include the unrevalued dollar balance of the acquired reserves in its…
1Opinion of the Court
National Savings Life Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
National Sav. Life Ins. Co. v. Commissioner
Docket No. 22379-80
United States Tax Court
84 T.C. 509; 1985 U.S. Tax Ct. LEXIS 103; 84 T.C. No. 36;
March 28, 1985. March 28, 1985, Filed
Decision will be entered under Rule 155.
Petitioner, a life insurance company under subch. L, I.R.C. 1954, acquired life insurance reserves from Progressive, also a life insurance company under subch. L, I.R.C. 1954, pursuant to a statutory merger. Petitioner had elected under sec. 818(c), I.R.C. 1954, to revalue its…
2Cases cited12 opinions
- Colony, Inc. v. CommissionerSupreme Court of the United States · 1958
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Waterman Steamship Corp. v. United StatesSupreme Court of the United States · 1965
- Taft v. HelveringSupreme Court of the United States · 1940
- Lincoln National Life Insurance v. United StatesUnited States Court of Claims · 1978
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