26 U.S.C. § 804

Life insurance deductions

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For purposes of this part, the term “life insurance deductions” means the general deductions provided in section 805.

Notes of Decisions

Cited in 16 cases, 1977–2002 · leading case: The Union Central Life Insurance Company, Cross-Appellant v. Commissioner of Internal Revenue, Cross-Appellee

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The Union Central Life Insurance Company, Cross-Appellant v. Commissioner of Internal Revenue, Cross-Appellee (1983) ca6 · cites it 3× “The Tax Court, 77 Tax Court 845, held that part of an Ohio franchise tax paid by the company was deductible under 26 U.S.C. § 804 (c)(1) rather than under 26 U.”

Indianapolis Life Ins. Co. and Subsidiary v. United States (1996) insd · cites it 4× “26 U.S.C. § 804 (a)(2) (1982) (emphasis added) (amended by 26 U.”

Principal Mutual Life Insurance Company v. The United States, Defendant/cross-Appellant (1995) cafc “1 In contrast, the court held that the fees paid by Principal to reimburse the costs of an Iowa state examination of its business affairs and financial condition were deductible in those tax years as “investment expenses” under 26 U.S.C. § 804 (c)(1) (1982). We affirm.”

The Prudential Insurance Company of America v. Commissioner of Internal Revenue (1989) ca3 · cites it 2× “Nevertheless, if Congress intended to treat these payments as interest for purposes of 26 U.S.C. § 804 , this congressional intent would control.”

The Travelers Insurance Company v. United States (2002) cafc “We hold that Congress explicitly provided for the exclusion of the policyholders’ share from LICTI in 26 U.S.C. §§ 804 (a)(1) and 809(a)(1) (1976), and accordingly reverse the decision of the Court of Federal Claims to the contrary.”

Ohio National Life Insurance v. United States (1986) cc “In deciding this issue, the court notes at the start that the statutory provision in question, 26 U.S.C. § 804 (c)(1), contains no definition or qualifying words respecting the type of general expense that may qualify for deduction as an investment expense.”

Security Benefit Life Insurance v. United States (1980) ksd “§ 802 (b) as the sum of— (1) the taxable investment income (as defined in 26 U.S.C. § 804 ) or, if smaller, the gain from operations (as defined in section 809), (2) if the gain from operations exceeds the taxable investment income, an amount equal to 50 percent of such excess,…”

Investment Annuity, Inc. v. Blumenthal (1977) dcd “In brief, the tax advantages of such treatment are: (1) the annual investment return of the segregated asset account is included not in the policyholder’s gross income, but rather in the investment yield of the insurance company, see 26 U.S.C. § 804 (c), with the result that…”

Massachusetts Mutual Life Insurance v. United States (1984) cc “26 U.S.C. § 804 (c)(2)-(4). . While a bad debt might also qualify as a section 162 expense for an ordinary business taxpayer, the term investment expense has been judicially interpreted, as will be shown, to exclude bad debts or losses on investments themselves.”

Liberty Life Insurance v. United States (1979) ca4 “Three issues are presented for our determination: (1) whether a portion of a South Carolina graded license fee may be described as an investment expense 1 within the meaning of that term as used in 26 U.S.C. § 804 (c)(1); (2) whether a portion of the commissions plaintiff paid…”

Liberty Life Insurance v. United States (1977) scd · cites it 2× “The dispute arises from the adoption by Liberty Life of a novel accounting method whereby certain items are considered to be investment expenses within the meaning of 26 U.S.C. § 804 (c)(1). The United States asserts by way of set-off, a claim for taxes not paid for the year…”

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