United States v. Occidental Life Insurance Company of California, a California Corporation

385 F.2d 1, 20 A.F.T.R.2d (RIA) 5678, 1967 U.S. App. LEXIS 4748
CourtCourt of Appeals for the Ninth Circuit
DecidedOctober 26, 1967
Docket21039_1
StatusPublished
Cited by18 cases

This text of 385 F.2d 1 (United States v. Occidental Life Insurance Company of California, a California Corporation) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Occidental Life Insurance Company of California, a California Corporation, 385 F.2d 1, 20 A.F.T.R.2d (RIA) 5678, 1967 U.S. App. LEXIS 4748 (9th Cir. 1967).

Opinion

ELY, Circuit Judge:

The Government appeals from a District Court judgment which awarded taxpayer a refund of federal income taxes for the taxable years 1954 and 1955. 1 Suit was instituted by the taxpayer pursuant to 28 U.S.C. § 1346(a) (1) after its claims for refund had been rejected. Our jurisdiction rests upon 28 U.S.C. § 1291.

The taxpayer is a stock life insurance company. For taxable years beginning in 1954, such companies were subject to *2 a tax equal to certain percentages of “1954 life insurance company taxable income.” Section 805(a) of the Internal Revenue Code of 1954, ch. 736, 68A Stat. 258, provided that “the term ‘1954 life insurance company taxable income’ means the taxable income * * *, plus 8 times the amount of the adjustment for certain reserves provided in section 806, and minus the reserve interest credit * * Computation of the “adjustment for certain reserves” was fixed in section 806 of the Code, which provided:

“In the case of a life insurance company writing contracts other than life insurance or annuity contracts (either separately or combined with noncancellable health and accident insurance), the term ‘adjustment for certain reserves’ means an amount equal to 314 percent of the unearned premiums and unpaid losses on such other contracts which are not included in life insurance reserves (as defined in section 803(b). For purposes of this section, such unearned premiums shall not be considered to be less than 25 percent of the net premiums written during the taxable year on such other contracts.”

Int.Rev.Code of 1954, § 806, ch. 736, 68A Stat. 259 (formerly Int.Rev.Code of 1939, § 202(c), as amended, ch. 619, § 163(a), 56 Stat. 870 (1942)).

In computing its “adjustment for certain reserves” so as to determine its taxable income for the year 1954, the taxpayer included as “unpaid losses” the December 31, 1953, to December 31,1954, mean of its “reserve for amounts not yet due on claims and for future contingent benefits,” an account representing unaccrued liabilities on its cancellable health and accident policies. 2 Omitted from this computation, however, was the amount of $4,707,914.46, which represented the mean, for the same period, of taxpayer’s accrued but unpaid - liabilities on such non-life policies. 3 The Commissioner ruled that the last mentioned amount should have been included within “unpaid losses” in determining taxpayer’s “adjustment for certain reserves” and assessed a deficiency of $79,563.76. The District Court held that the taxpayer’s accrued but unpaid liabilities arising from its cancellable health and accident policies were not properly treated as “unpaid losses” and awarded a refund of the assessment, plus interest.

Appellee also sought refunds on the basis of section 841 of the Internal Revenue Code of 1954, which provides, “The taxes imposed by foreign countries * * * shall be allowed as a credit against the tax of a domestic insurance company * * * to the extent provided in the case of a domestic corpora *3 tion in section 901 * * Section 901(b) (1) of the 1954 Code allows as a credit “the amount of any income, war profits, and excess profits taxes paid * * * to any foreign country * * Furthermore, section 903 extends this credit to “a tax paid in lieu of a tax on income, war profits, or excess profits otherwise generally imposed by any foreign country * *

This second refund claim involves both 1954 and 1955, during which years the taxpayer paid certain taxes to the Dominion of -Canada and to the Province of Quebec. The Dominion tax, levied pursuant to the Dominion Excise Tax Act, Can.Rev.Stat. c. 100, § 4(1) (1952), was equal to two percent of net premiums received from policy holders resident in Canada, less a credit equal to the Quebec tax. The latter was prescribed by the Quebec Corporation Tax Act, Statutes of Quebec, 11 Geo. 6, c. 33, § 3(3) (1947), and equalled two percent of net premiums received from life insurance business in Quebec. The District Court awarded refunds of $58,599.94 and $77,-434.01, plus interest, for the respective years 1954 and 1955, on the ground that appellee was entitled to credit under section 841 for its payment of these Canadian taxes.

The two questions which confront us, therefore, are as follows:

1. In computing its “adjustment for certain reserves,” was the taxpayer required to include as “unpaid losses” the amount of its accrued but unpaid non-life policy liabilities, as well as the amount of its unaccrued claims?

2. Were the Canadian premiums taxes imposed upon and paid by the taxpayer either income taxes or taxes paid in lieu thereof, so as to be allowable as foreign tax credits ?

UNPAID LOSSES

The scope of the term “unpaid losses” has been previously considered in Prudential Ins. Co. of America v. United States, 319 F.2d 161, 165-166, 162 Ct.Cl. 55, 65 (1963). There, the Court of Claims specifically held that the term “unpaid losses” as used in section 806 includes accrued but unpaid liabilities, in addition to similar unaccrued claims. The taxpayer contends, as the District Court indicated, that this decision lacks persuasive force because the court there did not specifically deal with many contentions which the present taxpayer has advanced. Even so, we are convinced that the Court of Claims reached the correct conclusion.

In order to understand the significance of “unpaid losses” as used in section 806, it is necessary to review the development of the method of taxation of life insurance companies which existed in 1954. 4 After 1921, life insurance companies were not required to include the amount of premiums received in the computation of their gross incomes. Under section 803 (a) (2) of the 1954 Code, ch. 736, 68A Stat. 256, as well as under the provisions of the prior law, 5 life insurance company gross income was confined to “interest, dividends, and rents.” This treatment represented recognition of the unique nature of a life insurance company’s underwriting business.

Many forms of insurance involve short-term, cancellable contracts, wherein the premium rate may be periodically adjusted to reflect the current risk. In contrast, premiums received on level- *4 premium life insurance policies represent both the cost of protection for the year of receipt and also the cost of establishing or enhancing a reserve fund, which must be accumulated at interest to provide protection for future years, since the event insured against is certain to occur and since the probability of occurrence increases with each successive year.

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385 F.2d 1, 20 A.F.T.R.2d (RIA) 5678, 1967 U.S. App. LEXIS 4748, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-occidental-life-insurance-company-of-california-a-ca9-1967.