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Article: Trans City Life Insurance Company, an Arizona corporation, petitioner v. Commissioner of Internal Revenue, respondent
- Article from:
- United States. Tax Court. Reports
- Article date:
- April 1, 1996
- Author:
CopyrightCopyright Superintendent of Documents Apr 1-Apr 30, 1996. Provided by ProQuest LLC. (Hide copyright information)
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Docket Nos. 23678-93, 16934-94. Filed April 30, 1996. P is an insurance company authorized to sell disability and life insurance within the State of Arizona. P's primary and predominant business activity is writing credit life and disability insurance policies. During the subject years, P and G,
an unrelated entity, entered into two retrocession (reinsurance) agreements for valid and substantial business reasons. Under the terms of each agreement, G retroceded its position on reinsurance to P, and P agreed to pay G a $1 million ceding commission. The agreements helped P qualify as a life insurance company under sec. 816, I.R.C., which, in turn, allowed P to claim the small life insurance ...