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American Mutual Life Insurance Co. v. United States

Summary judgment in favor of IRS affirmed; because life insurance reserve releases are not "fundamentally inconsistent" events and because plaintiff received a benefit from the reserve deductions taken, it could not resort to the tax benefit rule to exclude from income amounts corresponding to release of those reserves.

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Appealed from: United States Court of Federal Claims Chief Judge Lawrence M. Baskir

DECISION

American Mutual Life Insurance Co. (“American Mutual”) appeals from a grant of summary judgment by the United States Court of Federal Claims finding that income resulting from releases in life insurance reserves was required to be included as taxable income because the tax benefit rule is unavailable where the event, in this case the releases, does not meet the “fundamental inconsistency” test and where the taxpayer receives a tax benefit. Am. Mut. Life Ins. Co. v. United States, 46 Fed. Cl. 445 (2000). For the reasons discussed below, we affirm.

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