Ronan State Bank v. Commissioner
United States Tax Court
Pursuant to contracts negotiated with New York Life as insurer, Montana Bankers Association was named policyholder of group creditor life and health insurance policies obtained for its member banks. Borrowers could elect to purchase such group insurance at the time they obtained loans from petitioner who was a member of the Montana Bankers Association.
Read the full summary
Pursuant to contracts negotiated with New York Life as insurer, Montana Bankers Association was named policyholder of group creditor life and health insurance policies obtained for its member banks. Borrowers could elect to purchase such group insurance at the time they obtained loans from petitioner who was a member of the Montana Bankers Association. As a participating creditor under the group policies, petitioner, through its employees, performed all the activities required to market the insurance coverage and to service the group policy. Believing that local law prohibited its engaging in…
1Opinion of the Court
Gorfe, Judge:
Respondent determined deficiencies in the Federal income taxes of the petitioner as follows:
Calendar
year Deficiency
1967 _$7,656.16
1968 _ 2,593.55
1969 _ 3,778.42
1970 _ 3,095.45
The petitioner 'has conceded certain adjustments made in the statutory notice of deficiency. The only issue remaining for decision is whether income from participation in a creditors’ group insurance policy was taxable to petitioner, or to petitioner’s two controlling stockholders as individuals.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and attached exhibits are…
2Cases cited13 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- James v. United StatesSupreme Court of the United States · 1961
- United States v. BasyeSupreme Court of the United States · 1973
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
8 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Fritschle v. CommissionerUnited States Tax Court · 1982
- Davis v. CommissionerUnited States Tax Court · 1975
- Sorrell v. CommissionerUnited States Tax Court · 1987
- McIver v. CommissionerUnited States Tax Court · 1977
- Millette & Associates, Inc. v. CommissionerUnited States Tax Court · 1978
4 more not listed; retrieve them via the Exa API.