Legal Opinion

Reserve Loan Life Ins. Co. v. Commissioner

United States Board of Tax Appeals

Decided November 29, 1929No. Docket Nos. 21489, 29554, 32965PublishedCited by 11 opinions

1. The petitioner issues certain life insurance policies known as "guaranteed premium reduction policies." To such policies are attached coupons.

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1. The petitioner issues certain life insurance policies known as "guaranteed premium reduction policies." To such policies are attached coupons. Upon each annual premium-paying date a coupon matures, which may be turned in to the company in payment of the premium to the amount of the face value of the coupon, or if the premium is paid in full in cash the policyholder may use the coupon to purchase nonparticipating paid-up additions to the face of the policy or the coupon may be collected at any time with interest. In some of the policies the coupons may be used to reduce the number of…

1Opinion of the Court

*364OPINION.

TRAmmell:

In the original petitions filed in these proceedings and in the amended petitions filed prior to the hearing, the petitioner alleges that the respondent erred in eliminating the deductions taken for reserves to cover liability on outstanding coupons attached to guaranteed premium reduction policies. At the hearing the petitioner filed an amendment to its petitions, wherein it asked that it be allowed as deductions in determining net income the amounts paid and credited during the respective years to the holders of coupon policies, and stated that this was “ rather an…

2Cases cited1 opinion

  1. National Life Insurance v. United StatesSupreme Court of the United States · 1928

3Cited by11 opinions

  1. Penn Mut. Life Ins. Co. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1937
  2. Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Illinois Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Atlas Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. St. Louis Mut. Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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