Midland Nat'l Life Ins. Co. v. Commissioner
United States Tax Court
Under the Life Insurance Company Income Tax Act of 1959, it is held: 1. Deferred and uncollected premiums, including loading, are includable in "assets" under sec. 805(b)(4), I.R.C. 1954, for purposes of computing the tax on petitioner's investment income (phases I and II). 2. Deferred and uncollected premiums are includable in "gross amount of premiums" under sec. 809(c)(1), I.R.C. 1954, for purposes of computing the tax on petitioner's gain or loss from operations (phase…
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Under the Life Insurance Company Income Tax Act of 1959, it is held: 1. Deferred and uncollected premiums, including loading, are includable in "assets" under sec. 805(b)(4), I.R.C. 1954, for purposes of computing the tax on petitioner's investment income (phases I and II). 2. Deferred and uncollected premiums are includable in "gross amount of premiums" under sec. 809(c)(1), I.R.C. 1954, for purposes of computing the tax on petitioner's gain or loss from operations (phase II). 3. Petitioner is not entitled to a deduction under sec. 809(d)(12), I.R.C. 1954, for the increase in loading and…
1Opinion of the Court
Featherston, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax in these consolidated cases:
Docket No. Year Deficiency
5939-73_ 1965 $295,315.06
10081-74_ 1969 14,326.00
Other issues having been the subject of concessions by the parties, the following remain for our resolution:(1) Whether, for purposes of section 805(b)(4)1 and for certain purposes in computing gain or loss from operations, petitioner must include in its “assets” any portion of deferred and uncollected premiums;(2) Whether petitioner must include deferred and uncollected premiums in the…
2Cases cited12 opinions
- Jefferson Standard Life Insurance Company v. United States of America, (Two Cases). Jefferson Standard Life Insurance Company v. United States of America, (Two Cases)Court of Appeals for the Fourth Circuit · 1969
- The Franklin Life Insurance Company v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
- Western National Life Insurance Company of Texas v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Western and Southern Life Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
7 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Anchor Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1989
- Midland Nat'l Life Ins. Co. v. CommissionerUnited States Tax Court · 1976