USAA Life Ins. Co. v. Commissioner
United States Tax Court
State regulatory authorities required P to maintain a minimum reserve for its universal life insurance policies equal to the total cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the States, two separate reserve amounts that together equaled the total cash surrender value. The annual statement represented one reserve amount as a preliminary term reserve and the other as an excess miscellaneous reserve.
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State regulatory authorities required P to maintain a minimum reserve for its universal life insurance policies equal to the total cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the States, two separate reserve amounts that together equaled the total cash surrender value. The annual statement represented one reserve amount as a preliminary term reserve and the other as an excess miscellaneous reserve. P contends that the purported preliminary term reserve was subject to the revaluation provisions of sec. 818(c), I.R.C.…
1Opinion of the Court
USAA Life Insurance Co., Petitioner v. Commissioner of Internal Revenue, Respondent
USAA Life Ins. Co. v. Commissioner
Docket No. 18187-88
United States Tax Court
94 T.C. 499; 1990 U.S. Tax Ct. LEXIS 25; 94 T.C. No. 30;
March 26, 1990March 26, 1990, Filed
Decision will be entered for the respondent.
State regulatory authorities required P to maintain a minimum reserve for its universal life insurance policies equal to the total cash surrender value of the policies. P complied with this requirement by listing, in its annual statement filed with the States, two separate reserve amounts that together…
2Cases cited30 opinions
- United States v. PriceSupreme Court of the United States · 1960
- Helvering v. Inter-Mountain Life InsuranceSupreme Court of the United States · 1935
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- United States v. Consumer Life Insurance Co.Supreme Court of the United States · 1977
- Commissioner v. Standard Life & Accident InsuranceSupreme Court of the United States · 1977
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