Modern American Life Insurance v. Commissioner

818 F.2d 1386, 59 A.F.T.R.2d (RIA) 1133, 1987 U.S. App. LEXIS 6189
CourtCourt of Appeals for the Eighth Circuit
DecidedMay 13, 1987
DocketNos. 86-1636, 86-1779
StatusPublished
Cited by4 cases

This text of 818 F.2d 1386 (Modern American Life Insurance v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Modern American Life Insurance v. Commissioner, 818 F.2d 1386, 59 A.F.T.R.2d (RIA) 1133, 1987 U.S. App. LEXIS 6189 (8th Cir. 1987).

Opinion

MORRIS SHEPPARD ARNOLD, District Judge.

I.

Taxpayer, a Missouri corporation, is the surviving corporation in a merger with Dynamic Security Life Insurance Company (Dynamic).1 On December 29, 1978, Dynamic entered into a reinsurance agreement with Ozark National Life Insurance Company (Ozark) with respect to a portion of the latter’s policies. Under that agreement, which was denominated a “modified coinsurance agreement,”2 Dynamic, as the reinsurer, assumed 9.3 percent of Ozark’s liabilities on an existing block of whole life insurance policies for the period those policies remained in force and would thereafter be entitled to 9.3 percent of the future net gain from operations attributable to the [1388]*1388policies in question. The agreement further provided that Dynamic would pay Ozark an amount, designated as a “ceding commission,” of $450,000 as consideration for the rights acquired by it under the transaction. The effective date of the agreement was December 31, 1978, and the ceding commission was paid on December 29, 1978.

In accordance with the nature of the agreement as a modified coinsurance contract, Ozark remained directly liable to the policyholders on the reinsured business. The policyholders were not notified of the reinsurance agreement, and Ozark continued to collect the premiums and service the policies. The reserves for the policies continued to be held exclusively by Ozark.

On its federal income tax return for 1978, Dynamic deducted the $450,000 payment under “other deductions” as “modified coinsurance expense.” Upon examination, the Commissioner determined that no portion of that payment was deductible in 1978, but that, instead, the payment should be amortized, beginning in 1979, over the estimated 10-year life of the block of policies in question. Accordingly, the Commissioner determined a deficiency in taxpayer’s federal income taxes for 1978 in the amount of $153,842.

Taxpayer thereupon petitioned the Tax Court for a redetermination of the deficiency. The parties submitted cross-motions for summary judgment on the issue of the proper treatment of the ceding commission. The Tax Court granted summary judgment to taxpayer, holding that the ceding commission was currently deductible. The Tax Court recognized that such a commission would have to be amortized over the estimated life of the policies in the case of an assumption reinsurance transaction, but, relying on its earlier opinion in Beneficial Life Insurance Co. v. Commissioner, 79 T.C. 627 (1982), ruled that a ceding commission paid to the reinsured in an indemnity reinsurance transaction may be deducted in full in the year of payment as a return premium under Section 809(c)(1) of the Internal Revenue Code of 1954.

The Commissioner now appeals. We reverse.

II.

We note that while Beneficial Life did involve both conventional and modified coinsurance agreements, the court analyzed each agreement as if it were a conventional coinsurance agreement. See Beneficial Life, 79 T. C. at 634. This was proper because the parties to the modified coinsurance agreements there elected, pursuant to 26 U.S.C. § 820, to have their agreements treated, for tax purposes, as conventional coinsurance agreements. Id. The parties in the instant case, however, consented to no such election and this difference may be significant. A reinsuring company in a conventional coinsurance arrangement assumes liability on the policies being reinsured and sets up reserves to cover these acquired risks; but in a modified coinsurance arrangement the ceding company retains the assets attributable to the transaction and continues to carry the reserves on its books. The tax consequences are that the reinsurer in a conventional coinsurance agreement must, pursuant to 26 U. S.C. § 809(c)(1), include in income the assets actually or constructively transferred from the ceding company to the reinsuring company,3 and can, pursuant to 809(d)(2), deduct in full its increase in required reserves. Beneficial Life holds that because the consideration or allowance paid by the reinsurer to the ceding company for the reinsurance business ceded was simply being offset or netted by the ceding company against the assets transferred to the reinsurer to cover the reserves, the disparity between the amount of reserves assumed and actual consideration received from the ceding company should be treated as a payment back to the ceding company, and, pursuant to Section 809(c)(1), such amount could be deducted as a “return premium.” This amount [1389]*1389represents the present value of the acquired policies. The facts of Beneficial Life are therefore not before us, and thus we express no opinion as to the correctness of the result in that case.

III.

The effect of the Tax Court’s holding below is to grant taxpayer a current deduction for the cost of acquiring a future income stream equal to 9.3 percent of Ozark’s future earnings on these policies. Stripped of technicalities, the question on appeal reduces to whether the taxpayer may treat the acquisition of that future income stream as generating an immediate deduction, or whether, as in the case of assumption reinsurance, such amounts should be amortized over the estimated life of the future income stream acquired as a result of that expenditure.

It is, of course, a fundamental proposition of the tax law that expenses incurred in acquiring an asset or economic interest, benefit or advantage — whether tangible or intangible — with an income-producing life extending substantially beyond the current taxable year may not be ex-pensed in the year of payment but must be depreciated or amortized over its useful life.4 See 26 U.S.C. § 263; Commissioner v. Idaho Power Co., 418 U.S. 1, 12, 94 S.Ct. 2757, 2764, 41 L.Ed.2d 535 (1974); United States v. Mississippi Chemical Corp., 405 U.S. 298, 309, 92 S.Ct. 908, 914, 31 L.Ed.2d 217 (1972); Commissioner v. Lincoln Savings & Loan Assn., 403 U.S. 345, 354, 91 S.Ct. 1893, 1899, 29 L.Ed.2d 519 (1971); Woodward v. Commissioner, 397 U.S. 572, 574-575, 90 S.Ct. 1302, 1304, 25 L.Ed.2d 577 (1970); United States v. Akin, 248 F.2d 742, 744 (10th Cir.1957); General Bancshares Corp. v. Commissioner, 326 F.2d 712 (8th Cir.1964) cert. denied, 379 U.S. 832, 85 S.Ct. 62, 13 L.Ed.2d 40 (1964); Darlington-Hartsville Coca-Cola Bottling Co. v. United States, 393 F.2d 494, 496 (4th Cir.1968), cert.

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Bluebook (online)
818 F.2d 1386, 59 A.F.T.R.2d (RIA) 1133, 1987 U.S. App. LEXIS 6189, Counsel Stack Legal Research, https://law.counselstack.com/opinion/modern-american-life-insurance-v-commissioner-ca8-1987.