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PHOENIX MUTUAL LIFE INS. CO. v. COMMISSIONER

Docket No. 31993-87.

96 T.C. 481 (1991)

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

United States Tax Court.

Filed March 12, 1991.

Attorney(s) appearing for the Case

Arthur L. Bailey, Gerald A. Kafka, and J. Walker Johnson, for the petitioners.

Diane D. Helfgott, for the respondent.

WELLS, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the year ended December 31, 1980, in the amount of $6,223,612.

The only issue we consider in this opinion1 is whether "prepayment premiums" received by petitioner upon the early retirement of mortgage loans made to corporate obligors constitute long-term capital gain excluded from gross investment income under section 804(b).

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