Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 24
Page 276
... Guardian Life Insurance Co. of America ( Guardian ) . Respondent asserted in her amendments that the 1989 through 1992 deficiencies were $ 672,210 , $ 553,533 , $ 437,584 , and $ 354,246 , respectively . We must decide : 1. Whether ...
... Guardian Life Insurance Co. of America ( Guardian ) . Respondent asserted in her amendments that the 1989 through 1992 deficiencies were $ 672,210 , $ 553,533 , $ 437,584 , and $ 354,246 , respectively . We must decide : 1. Whether ...
Page 278
... Guardian Life Insurance Company of America has a significant tax avoidance effect with respect to the Trans City Life Insurance Company . Pursuant to Internal Revenue Code section 845 an adjustment is made to reserves to eliminate the ...
... Guardian Life Insurance Company of America has a significant tax avoidance effect with respect to the Trans City Life Insurance Company . Pursuant to Internal Revenue Code section 845 an adjustment is made to reserves to eliminate the ...
Page 283
... Guardian ( as the reinsurer ) .7 The agreements were mainly surplus relief reinsurance agreements , and petitioner's ... Guardian agreed that the first agreement ( the 1988 agreement ) , executed on December 29 , 1988 , was effective ...
... Guardian ( as the reinsurer ) .7 The agreements were mainly surplus relief reinsurance agreements , and petitioner's ... Guardian agreed that the first agreement ( the 1988 agreement ) , executed on December 29 , 1988 , was effective ...
Page 284
... Guardian to terminate the agreements under any circumstance . Before January 2 , 1990 , and January 2 , 1991 , Guardian could not recapture any of the policies underlying the 1988 agreement and the 1989 agreement , respectively ...
... Guardian to terminate the agreements under any circumstance . Before January 2 , 1990 , and January 2 , 1991 , Guardian could not recapture any of the policies underlying the 1988 agreement and the 1989 agreement , respectively ...
Page 285
... Guardian did leave the reinsurance in place , the risk of loss would have remained with petitioner . Guardian's unilateral right to terminate the agreements increased rather than decreased petitioner's risk . Throughout the duration of ...
... Guardian did leave the reinsurance in place , the risk of loss would have remained with petitioner . Guardian's unilateral right to terminate the agreements increased rather than decreased petitioner's risk . Throughout the duration of ...
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Common terms and phrases
1989 agreement 9th Cir affd allocable alternative minimum tax amended apply Arkla assets benefits business expense cardholder CBOT Citibank cluster home Commis Commissioner Congress contract corporation cost Court of Appeals debt decedent decedent's deduction determined election employees estate tax executor Federal income tax filed funds gross income Guardian Income Tax Regs Internal Revenue Code investment Irwindale issue litigation loan Los Angeles Raiders Malibu marital deduction MasterCard meals ment Mexican pesos Nihon Intergraph obligation overdraft amount paid parties payment percent peti petitioner Petitioner argues petitioner's possession product purchase purposes pursuant QTIP Raiders received refund regulations reinsurance reinsurance agreement Rept respondent's rule statute summary judgment supra surviving spouse T.C. Memo tax avoidance Tax Court tax deficiencies tax return taxable income taxpayer Temporary Income Tax terminable interest tion tioner trade or business transaction transfer fees trust United VEBA