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USAA LIFE INSURANCE CO. v. COMMISSIONER

Docket No. 18187-88.

94 T.C. 499 (1990)

USAA LIFE INSURANCE CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1990.

Attorney(s) appearing for the Case

Glen H. Kanwit, Richard Bromley, Michael A. Clark, and R. Lee Christie, for the petitioner.

Avery Cousins III, for the respondent.

FEATHERSTON, Judge:

Respondent determined deficiencies in petitioner's Federal income tax in the amounts of $391,571.79 for 1982 and $2,225,593.60 for 1983. After concessions by petitioner, the principal issue for decision is (1) whether petitioner for 1983 was entitled to revalue, under section 818(c),1 certain of the reserves that corresponded to its universal life insurance policies....

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