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WORLD SERVICE LIFE INSURANCE CO. v. COMMR.

Docket No. 13692-84.

89 T.C. 70 (1987)

WORLD SERVICE LIFE INSURANCE COMPANY, AS SUCCESSOR BY MERGER TO GIBRALTAR LIFE INSURANCE COMPANY OF AMERICA, TRANSFEREE OF THE ASSETS OF PLANNED FUTURE LIFE INSURANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 9, 1987.

Attorney(s) appearing for the Case

William S. Lee, for the petitioner.

Val J. Albright, for the respondent.

OPINION

JACOBS, Judge:

Respondent determined a deficiency in income tax in the amount of $35,540.49 due from Planned Future Life Insurance Co. (PFLIC) for its short tax year January 1, 1974, to June 30, 1974. Petitioner concedes that it is liable for any tax deficiency determined to be due from PFLIC.1 The deficiency arose as a result of respondent's determination that the amount remaining in PFLIC's policyholders surplus...

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