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Commissioner v. Standard Life & Acc. Ins. Co., 433 U.S. 148 (1977)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Commissioner v. Standard Life & Acc. Ins. Co., 433 U.S. 148 (1977)
Commissioner v. Standard Life & Accident Ins. Co. No. 75-1771 Argued March 30, 1977 Decided June 23, 1977 433 U.S. 148
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE TENTH CIRCUIT
Syllabus
The "net valuation" portion of unpaid life insurance premiums (the portion state law requires a life insurance company to add to its reserve), but not the "loading" portion (the portion to be used to pay salesmen’s commissions, other expenses such as state taxes and overhead, and profits), held required to be included in a life insurance company’s assets and gross premium income, as well as in its reserves, for purposes of computing its federal income tax liability, notwithstanding such computation necessitates making a fictional assumption that the "net valuation" portion has been paid but that the "loading" portion has not. This treatment of unpaid premiums is in accordance with § 818(a) of the Internal Revenue Code of 1954 (as added by the Life Insurance Company Income Tax Act of 1959), which requires computations of a life insurance company’s income taxes to be made
in a manner consistent with the manner required for purposes of the annual statement approved by the National Association of Insurance Commissioners,
unless the NAIC procedures are inconsistent with accrual accounting rules, and to the extent that the Treasury Regulations require different treatment of unpaid premiums they are inconsistent with § 818(a), and therefore invalid. Pp. 152-163.
525 F.2d 786, reversed and remanded.
STEVENS, J., delivered the opinion of the Court, in which BRENNAN, MARSHALL BLACKMUN, POWELL, and REHNQUIST, JJ., joined. WHITE, J., filed an opinion concurring in the judgment, in which BURGER, C.J., joined, post, p. 163. STEWART, J., took no part in the consideration or decision of the case.
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Chicago: U.S. Supreme Court, "Syllabus," Commissioner v. Standard Life & Acc. Ins. Co., 433 U.S. 148 (1977) in 433 U.S. 148 433 U.S. 149. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=RPD8XDG2HFQ6YYR.
MLA: U.S. Supreme Court. "Syllabus." Commissioner v. Standard Life & Acc. Ins. Co., 433 U.S. 148 (1977), in 433 U.S. 148, page 433 U.S. 149. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=RPD8XDG2HFQ6YYR.
Harvard: U.S. Supreme Court, 'Syllabus' in Commissioner v. Standard Life & Acc. Ins. Co., 433 U.S. 148 (1977). cited in 1977, 433 U.S. 148, pp.433 U.S. 149. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=RPD8XDG2HFQ6YYR.
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