Boston Ins. Co. v. United States

58 Ct. Cl. 603, 4 A.F.T.R. (P-H) 3685, 1923 U.S. Ct. Cl. LEXIS 230, 1924 U.S. Tax Cas. (CCH) 2088, 1923 WL 2172
CourtUnited States Court of Claims
DecidedNovember 5, 1923
DocketNo. B-166
StatusPublished

This text of 58 Ct. Cl. 603 (Boston Ins. Co. v. United States) is published on Counsel Stack Legal Research, covering United States Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boston Ins. Co. v. United States, 58 Ct. Cl. 603, 4 A.F.T.R. (P-H) 3685, 1923 U.S. Ct. Cl. LEXIS 230, 1924 U.S. Tax Cas. (CCH) 2088, 1923 WL 2172 (cc 1923).

Opinion

Booth, Judge,

delivered the opinion of the court:

The plaintiff insurance company is a Massachusetts corporation engaged in writing fire and marine insurance. Among other States in which it transacts business is the State of New York, and in order to do so it must comply with the laws of New York relating to a foreign insurance company seeking to write insurance in that State. This the plaintiff did. It acceded to all the requirements exacted [611]*611of it by the superintendent of insurance and did a large volume of business within that State.

The plaintiff company filed with the Commissioner of Internal Revenue its income-tax return for the year 1916, and on June 15, 1917, paid under protest the tax assessed thereon, amounting to $3,982. Subsequently, on December 8, 1917, the commissioner assessed against the company an additional income tax on the previous return filed of $16,790.65, and on December 18, 1917, this additional tax was paid under protest. On April 80, 1920, plaintiff filed with the commissioner a claim for a refund of the entire sum, viz, $20,772.65, paid as aforesaid, asserting a right thereto under the law. The commissioner refunded $12,016.73 of the tax and rejected the refund claim as to $8,775.92, and it is for the recovery of this sum that the present suit is brought.

The superintendent of insurance of the State of New York exacted of the plaintiff the maintenance of a net addition to its reserve funds of $560,678.43 on account of its liability for unsettled loss claims for the year 1916, and it is stipulated that said said sum was duly added by the plaintiff to meet the requirement. The commissioner treated said net addition to reserve funds as income for the calendar year and assessed and collected the sum herein claimed as an income tax lawfully due thereon.

Section 12 of the revenue act of September 8, 1916, 39 Stat. 765, in subsection (c) provides in the following language for a deduction from the gross income of insurance companies organized in the United States, of “ the net addition, if any, required by law to be made within the year to reserve funds and the sums other than dividends paid within the year on policy and annuity contracts.” The defendant relied upon the above statute for authority to proceed as it did.

The one question, and the only one properly raised, is whether, within the meaning and intent of the Federal revenue act, the net additions so made by the plaintiff to its reserve funds in pursuance of the requirements of the superintendent of insurance for New York, to cover accrued but unsettled loss claims, may be said to be such a fund as [612]*612comes Avithin the meaning of “ reserve funds,” as those terms appear in the revenue act.

The defendant does not dispute that the sum involved Avas reserved, nor that it was required by the proper insurance authorities of New York to be reserved. Defendant’s argument is predicated upon an assertion that Congress in exempting net additions to reserve funds, clearly intended to exempt only such funds as are technically known and univei’sally understood in the insurance world as reserve funds, and as thus understood the terms have a well defined, limited, and certain status and meaning. We may well grant the contention, but apparently it furnishes no solution for the issue, unless we may find some authoritative decision that unsettled loss claims are not within the meaning of “ reserve funds,” as thus contended for.

Mr. Justice Clarke, in the case of Maryland Casualty Co. v. United States, 251 U. S. 342, 350, defines the terms “ reserve ” and “ reserves,” and the definition therein given Avas elicited by a contention in all respects similar to the one noAv at issue. “ The term reserve ’ or ‘ reserves ’ has,” he says, “ a special meaning in the law of insurance. While its scope varies under different laws, in general it means a sum of money, variously computed or estimated, which, with accretions from interest, is set aside, ‘ reserved,’ as a fund with which to mature or liquidate, either by payment or reinsurance with other companies, future unaccrued and contingent claims, but contingent and indefinite as to amount or time of payment.” In that case, and following the definition thus announced, the Supreme Court did include a loss claims item as part of the reserve required by law to be maintained by' tlie insurance company.

It is true that the insurance laws of New York did not expressly require that such a reserve be maintained, but the regulations of the superintendent of insurance of that State, in pursuance of a most general and plenary authority so to do, did exact it, and disobedience of the insurance laws precluded the conduct of any insurance business in the State by a foreign insurance company. In the Maryland Casualty Co. case, just cited, the Supreme Court decided that regulations of a department of a State government, [613]*613adapted to the enforcement of an act of that State, had the force and effect of law.

It is difficult, indeed, in view of the above decision, or upon any other logical hypothesis, to exactly comprehend any reason for excluding loss claims items from a legal reserve under the section of the revenue act heretofore quoted. Congress, of course, intended to tax the net income of the insurance company, and in providing exemptions from its gross income was especially concerned with relieving from the tax burden the sums of money or assets of the company which it was obligated by law to set aside as a guaranty and protection to its policyholders. There was manifestly no difficulty in arriving at fixed expenditures and disbursements actually made by the company, but contingent liabilities, contingent claims, and payments of same, an inseparable concomitant of the business itself, was the problem Congress was seeking to solve. If a sum of money had to be set aside and reserved out of gross income to meet a contingent, liability it was an act of .obvious fairness to treat that sunn as exempt from the computations to ascertain net income until the contingency ceased to exist and the liability was discharged. ' As said in the Maryland Casualty Co. case, suyra, when the reserves are released “ to free beneficial use of the company in a real, and not a mere bookkeeping sense,” they are income.

A loss claims reserve is the setting aside of a sufficient sum or assets of the insurance company to assure the final liquidation of losses not yet reported and to be adjusted. The final payment of a loss depends upon a variety, of circumstances. It may be a partial or a total loss; it may involve a contest extending over a long period of time, and many other contingencies may intervene which necessarily require adequate protection for the loser, that in the end his loss, whatever it is, may be made good under the terms of his policy. Assuredly loss claims are to be classified as a liability of the company. For what other purpose are reserves demanded. other than as an assurance against liability ? In this respect the situation is not essentially different from an unearned premium reserve. An'insurance company 'receives a large sum of money as paid premiums upon its policies. [614]*614When tbe premiums are paid contingent liability under tbe policies attach, and the defendant concedes that a reserve of sufficient proportions to cover reinsurance in the event of insolvency is within the meaning and intent of reserves

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Related

Maryland Casualty Co. v. United States
251 U.S. 342 (Supreme Court, 1920)
People, Ex Rel. Hartford L. Ins. Co. v. . Fairman
91 N.Y. 385 (New York Court of Appeals, 1883)

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58 Ct. Cl. 603, 4 A.F.T.R. (P-H) 3685, 1923 U.S. Ct. Cl. LEXIS 230, 1924 U.S. Tax Cas. (CCH) 2088, 1923 WL 2172, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boston-ins-co-v-united-states-cc-1923.