# Old Equity Life Ins. Co. v. Commissioner

> United States Tax Court · October 18, 1976 · 67 T.C. 48

URL: https://www.frixlaw.com/law-library/cases/4483227

## Case

- **Full name:** Old Equity Life Insurance Company v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** October 18, 1976
- **Citations:** 67 T.C. 48; 1976 U.S. Tax Ct. LEXIS 39
- **Precedential status:** Published
- **Opinion:** Concurrence by Simpson
- **Judges:** Wilbur,Simpson,Raum,Tannenwald
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4483227

## Opinion text

Simpson, J., concurring: Section 1508(a) of the Tax Reform Act of 1976, 90 Stat. 1520 , 1741, has amended section 809(d)(5) by adding the following sentence:
For purposes of this paragraph, the period for which any contract is issued or renewed includes the period for which such contract is guaranteed renewable.
Such amendment is applicable to taxable years beginning after December 31,1957. Tax Reform Act of 1976, sec. 1508(b). In the light of this amendment, I agree with the result of the majority and find it unnecessary to express any views concerning the interpretation of the statute prior to its amendment.
Raum and Tannenwald, JJ., agree with this concurring opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4483227. Public record. Not legal advice.