United Fire Ins. Co. v. Commissioner

81 T.C. No. 26, 81 T.C. 368, 1983 U.S. Tax Ct. LEXIS 39
CourtUnited States Tax Court
DecidedSeptember 19, 1983
DocketDocket No. 202-80
StatusPublished
Cited by4 cases

This text of 81 T.C. No. 26 (United Fire Ins. Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United Fire Ins. Co. v. Commissioner, 81 T.C. No. 26, 81 T.C. 368, 1983 U.S. Tax Ct. LEXIS 39 (tax 1983).

Opinions

Wilbur, Judge:

Respondent determined deficiencies in petitioner’s Federal income tax as follows:

Year Deficiency
1970 . $788.05
1971 . 2,476.09
1972 . 2,121,986.69

After concessions,1 the sole issue for decision is whether petitioner qualified as a life insurance company under section 801(a)2 during the years 1973, 1974, and 1975. The resolution of this issue turns on whether certain of petitioner’s individual health and accident insurance policies, with respect to which petitioner valued mid-terminal reserves on the 2-year preliminary term basis, qualified as "noncancellable” or "guaranteed renewable” within the meaning of sections 1.801-3(c) and 1.801-3(d), Income Tax Regs.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulations of fact, together with the exhibits attached thereto, are incorporated herein by this reference.

United Fire Insurance Co. (hereinafter referred to as petitioner) is a stock fire and casualty insurance corporation organized under New York law. Its principal place of business was Chicago, Ill., when the petition herein was filed. Petitioner filed its original Federal income tax returns for the calendar years 1970 through 1976 with the Internal Revenue Service Center at Kansas City, Mo. A copy of petitioner’s annual convention statement (hereinafter referred to as the annual statement) was attached to each of its original returns.3 After filing its original returns for 1970, 1971, and 1972, petitioner filed amended returns for each year and a second amended return for 1972, all with the Internal Revenue Service Center at Kansas City, Mo. At all times here pertinent, petitioner’s primary and predominant business activity has been the issuance of policies or contracts of insurance and the reinsurance of risks underwritten by other insurance companies.

Prior to 1969, petitioner was a specialty insurer, writing exclusively policies covering risks of fire and extended coverage on weekly or industrial debit plans. In early 1969, petitioner adopted a policy of expansion and diversification under which it planned to enter into the accident and health insurance field. In 1968, pursuant to this plan, petitioner commenced, inter alia, to issue and reinsure individual policies of accident and health insurance.

During the years 1973 through 1975, a substantial portion of its business consisted of issuing and reinsuring policies of accident and health insurance. Most of the accident and health insurance policies issued or reinsured by petitioner contained a rider, clause, or provision which entitled the insured, at his option, to renew or continue the policy in force either for life or to a specified age of at least 60 years. All of these renewable policies were "level premium” policies; that is, the premium rate throughout the duration of each policy was required to be determined by reference to the age and underwriting classification4 of the insured at the time the policy was first issued.

A small percentage of these policies guaranteed the insured the right to renew the policy at a specific, unadjustable premium rate; in the terminology of the insurance industry, this type of policy is known as "noncancellable.” Under most such policies, however, petitioner reserved the right to adjust the premium rates by policy class in accordance with its experience under the type of policy involved, to take into account such items as increased medical costs, but not changes in the age or underwriting classification of the insured. This type of policy is commonly known in the insurance industry as "guaranteed renewable.”5

Noncancelable and guaranteed renewable accident and health policies are recognized product types in the insurance industry. For purposes of classification by the insurance industry, the contractual provisions described in the preceding paragraph distinguish noncancelable and guaranteed renewable individual accident and health policies from other forms of accident and health insurance. All of petitioner’s individual noncancelable and guaranteed renewable policies satisfy the industry definition of that product type from the date those policies are issued, since the terms of those policies afford the insured the option to renew at level premiums until he or she reaches at least the age of 60.

The actuarial risks assumed by petitioner under its renewable policies increase with the age of the insured. Since petitioner may not adjust the premium rate to reflect these increased risks in the later years of such policies, the premium rate initially established represents, in effect, an actuarial average cost of insurance over the entire renewable period. During the early years of petitioner’s renewable policies, the level premiums charged are therefore larger than the actuarially anticipated cost of claims for those years, and during the later years of such policies, the level premiums are insufficient to cover actuarially anticipated claims for those years.

Thus, in establishing the premium rate to be charged for its renewable policies, petitioner must include both the actuarial cost of insuring the policyholder for the current periodic premium term as well as the long-term risks, actuarially computed, represented by petitioner’s promise to renew the policy at a level premium. In addition, petitioner must take into account the non-insurance costs associated with these policies in establishing the premium rate to be charged. In insurance industry parlance, the total premium charged for a policy of insurance (the "gross premium”) thus consists of two computational factors: the "net premium” and "loading.” The net premium is the actuarially computed amount of the gross premium designed to cover the cost of the insurance risk under the policy. Loading is the portion of the gross premium designed to cover petitioner’s non-insurance costs, such as commissions and administrative expenses, and also includes a margin for profit.

The insurance industry is regulated by State authority. One of the primary objectives of such State regulatory authority is to assure that companies falling within their jurisdiction are able to meet claims of policyholders as they fall due. In furtherance of this objective, such authorities establish minimum reserve requirements which insurance companies must comply with, and require such companies which engage in the insurance business in the State to file an annual statement reflecting such reserves.

One type of reserve here pertinent that State regulatory authority requires petitioner to establish with respect to its renewable policies is the "active life reserve,” which is a reserve maintained for claims which have not yet been incurred. The active life reserve consists of two components, carried and stated separately in the annual statement used by petitioner. The first component of the active life reserve is the "unearned premium reserve.” The second component of the active life reserve is the "additional reserve.”

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Related

National Sav. Life Ins. Co. v. Commissioner
84 T.C. No. 36 (U.S. Tax Court, 1985)
United Fire Ins. Co. v. Commissioner
81 T.C. No. 26 (U.S. Tax Court, 1983)

Cite This Page — Counsel Stack

Bluebook (online)
81 T.C. No. 26, 81 T.C. 368, 1983 U.S. Tax Ct. LEXIS 39, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-fire-ins-co-v-commissioner-tax-1983.