Your client, Ned Bovine, purchased a $ 2 million life insurance policy from the Nickel Life Insurance Co. (NLIC) of Dime Box, Texas. Ned’s wife is the beneficiary of the policy. The policy was purchased 10 years ago when Nickel Life Insurance was a mutual insurance company. In the current year, Nickel Life Insurance converted from a mutual company to a stock company in a tax-free reorganization. As part of the conversion, Ned received 800 shares of the new publicly traded (NASDAQ) Nickel Life Insurance Co. Three weeks after receiving the shares, Ned sold all his shares at $ 15 each. The total premiums paid by Ned on the policy before the conversion was $ 20,000.
a. Locate the IRS pronouncement(s) that deals with this situation. State the pronouncement number(s).
b. Review the IRS pronouncement(s). Does it raise a need for new information to solve this question?
c. Are you able to reach a conclusion about the research question from this IRS pronouncement(s)? If so, what is your conclusion(s)?