Equitable Life Assurance Soc. of US v. United States

181 F. Supp. 241, 149 Ct. Cl. 316, 5 A.F.T.R.2d (RIA) 916, 1960 U.S. Ct. Cl. LEXIS 26
CourtUnited States Court of Claims
DecidedMarch 2, 1960
Docket559-58—563-58
StatusPublished
Cited by18 cases

This text of 181 F. Supp. 241 (Equitable Life Assurance Soc. of US 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
Equitable Life Assurance Soc. of US v. United States, 181 F. Supp. 241, 149 Ct. Cl. 316, 5 A.F.T.R.2d (RIA) 916, 1960 U.S. Ct. Cl. LEXIS 26 (cc 1960).

Opinion

REED, Justice (Retired),

sitting by designation.

These are cross-motions for partial summary judgment under Rule 51 of this court, 28 U.S.C.A. Plaintiff seeks recovery of income taxes paid on mortgage and promissory note prepayment charges collected from borrowers during the years 1950-1954. The Commissioner of Internal Revenue has treated those prepayment charges collected during 1950-1953 as income under § 201(c) 1 of the Internal Revenue Code of 1939, 28 U.S.C.A. § 201(c), and as to those charges collected during 1954 the same result *242 was reached under § 803(a) (2) of the I.R.C. of 1954, 26 U.S.C.A. § 803(a) (2) 2

It is our judgment that the determination of the Commissioner was correct .and that the prepayment charges are within the class of items covered by the term “interest” in the definition of life insurance company gross income found in § 201(c) of the I.R.C. of 1939 and § 803(a) (2) of the I.R.C. of 1954 as it then existed.

It is common practice to include in long-term corporate promissory notes provisions imposing a prepayment charge if the borrower prepays the principal before the maturity of the loan. In plaintiff’s case this prepayment charge was based on a sliding scale ranging from three percent on the principal prepaid within five years of the loan to ■one-quarter of one percent on the principal prepaid in the nineteenth year of a loan. Plaintiff’s mortgages typically provide for a prepayment charge of one-half of one percent per annum on the amount prepaid in excess of twenty percent of the principal during the first five years of the mortgage. During the taxable years 1950 to 1954 plaintiff states that it received $3,289,822.29 in mortgage prepayment charges and $1,706,-.'531.00 in prepayment charges on corporate promissory notes.

The income taxation of life insurance companies presents unique problems. The cash receipts of life insurance companies consist of a return on invested funds as well as premiums and other receipts. It has long been recognized that ■only a small part of these total receipts resemble true income. 3 The vast bulk are accretions to reserve funds and will be returned eventually to the policyholders to indemnify them for the losses insured against. The Revenue Act of 1921 4 established the formula under which income taxation of life insurance companies is based on investment income to the exclusion of underwriting receipts. Taxable investment income was limited to “interest, dividends, and rents.” While income taxation of life insurance companies was repeatedly modified over the years, it retains its basic form. See the Life Insurance Company Income Tax Act of 1959, § 804(b) (l). 5

The precise question before us was considered by the Tax Court in General American Life Insurance Company, 1956, 25 T.C. 1265. That court decided that prepayment charges are in reality an additional fee for the use of the lender’s money for a shorter period of time than originally agreed upon, and that this fee represents the generally higher cost of a short-term, as opposed to a long-term loan. The charges are part of the compensation to the lender for the use of money. Deputy v. du Pont, 308 U.S. 488, 498, 60 S.Ct. 363, 84 L.Ed. 416; Old Colony R. Co. v. Commissioner, 284 U.S. 552, 560-561, 52 S.Ct. 211, 76 L.Ed. 484. They are thus directly related to the economic cost of borrowing money and are not merely incidental to the loan transaction, but fall within the statutory term “interest.”

This result conforms to the general object of those who formulated the Revenue Act of 1921. The Congress was approaching the problem of income taxation of life insurance companies from the standpoint of “investment income,” and this income was to be the basis of the tax. 6 We conceive of no reasonable *243 distinction between prepayment and other charges for the use of money from the point of view of whether they are part of investment income. It would not be consistent with the broad statutory language of § 201(c) to give the term “interest” the narrow definition plaintiff seeks. 7 Prepayment and other interest charges are both received for the use of the company’s capital and their rate is dependent in part on the length of time for which the capital is to be used. The 1956 amendments to the Code 8 modified the definition to specifically indicate that it includes prepayment charges. We do not view these amendments as working any substantial change in the scope of the statute in regard to this problem.

During the thirty-five years the § 201 (c) definition of life insurance company income was in effect, little authority accumulated on what is encompassed within the statutory term interest. Although the statute is in broad terms, it was not supplemented by regulations or revenue rulings. We have inquired of counsel as to the practice of the Commissioner and within the industry during the twenty-nine year period between the passage of the Revenue Act of 1921 and 1950, the first year here litigated. Plaintiff asserts, and we do not understand defendant to deny, that it was consistent and unchallenged practice of the plaintiff and other life insurance companies from 1921 to 1950 to exclude prepayment receipts from taxable income. There are several other eases involving years prior to the 1956 amendments presently in litigation, but all have been brought in recent years, indeed all have been brought since the statutory definition was amended. 9

The failure of the Commissioner to assert the taxability of these payments *244 for over a generation tends to support the inference that these payments were not considered within the statutory term “interest.” The want of assertion of power by those who presumably would be alert to exercise it has been considered significant in determining whether such power was actually conferred. 10 But we do not consider this negative inference sufficiently persuasive to form a basis for the construction of this statute sought by petitioner in view of the statutory purpose underlying income taxation of life insurance companies. We know of no positive evidence in the form of rulings, regulations, or requests to Congress for an extending amendment to the statute, leading us to the conclusion that any failure to assert a claim to these taxes was the result of a conscious decision on the part of the Commissioner. 11

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181 F. Supp. 241, 149 Ct. Cl. 316, 5 A.F.T.R.2d (RIA) 916, 1960 U.S. Ct. Cl. LEXIS 26, Counsel Stack Legal Research, https://law.counselstack.com/opinion/equitable-life-assurance-soc-of-us-v-united-states-cc-1960.