Independent Life & Accident Ins. Co. v. Commissioner of Internal Revenue

WALLER, Circuit Judge.

The sole question in each of these cases is whether or not the reserve maintained by the companies for the protection of the policy holders under the requirements of the Florida Statute (C.G.L., Florida, § 6264, F.S.A. §§ 626.11, 638.04) was such a reserve as would entitle the taxpayers during the taxable years to be defined as life insurance companies under Section 201(a) of the Revenue Acts of 1934 and 1936, 26 U.S.C.A. Int.Rev.Code, § 201(a).

Section 201(a) of the Revenue Act of 1934, which is identical with Section 201 (a) of the Revenue Act of 1936, is as follows r…