holds that an arrangement that provides for the reimbursement of inevitable future costs does not involve the requisite insurance risk for purposes of determining whether the amount paid for the arrangement is deductible as an insurance premium, and whether the assuming entity may account for the arrangement as an insurance contract for purposes of subchapter L. Stakeholders are asked to comment on the application of the rationale of the revenue ruling outside of its facts.
...1990) (insurance is an aleatory contract); Restatement (First) of Contracts § 291...
...("Eastbourne") for breach of contract following a bench trial. We affirm. Background. On... also contends that the Agreement is an aleatory contract which accordingly was not terminable upon...
Uncertainty about tax results is an ever-present obstacle to business transactions despite the extensive number of Internal Revenue Code sections and Treasury Regulations. Some insurance companies now provide an insurance product to protect taxpayers against adverse tax consequences from proposed transactions. Ironically, this new insurance product, labeled "tax insurance," poses uncertain tax consequences itself. This Article argues that if the adverse tax consequences arise (that is, the taxpayer has additional tax liability) and the insurance company is contractually required to cover that liability, the tax insurance proceeds are not includable in the insured's gross income. As part of the reasoning that underlies this conclusion concerning tax insurance, the Article examines and de...
... be regarded as a payment pursuant to an aleatory contract in which the insured receives a greater a...
... Aleatory Contracts An aleatory contract is a mutual agreem...
...,000 yearly renewable war risk insurance contract which he permitted to lapse after his honorable di...1287. A valid aleatory contract may be based on an unknown past event. 3 ...
Introduction II. The Cases A. Telerecovery of Louisiana, Inc. v. Major B. Telerecovery of Louisiana, Inc. v. Gaulon III. Analysis A. An Historical Perspective B. Cause v. Consideration C. Did the enactment of gaming legislation eliminate unlawful cause? D. Public Policy IV. Conclusions A. New Approach for Courts to Handle Gambling Debts B. Some Lessons for the Legislature 1. Other U.S. Jurisdictions 2. Civil Jurisdictions 3. Possible Initiatives for Casinos a. Criminal Law b. Self-Help
... civil actions for the recovery of contracts pertaining to gambling winnings and losses. 40 Lo... 2983 and 2984 appear in Title XIV, "of Aleatory Contracts," of Book III of the Civil Code. This Ti...
... stated in this subsection is limited to aleatory promises and does not apply if the promise is cond...
...Traditional contracts based on oral agreements known as l-khumus were pa..., how can they "run after" it? Facing the aleatory, Moroccans have developed the art of tinkering wit...
... to impose personal liability for a contractual obligation to pay money under § 502(a)(3), holdin... because this case involves an aleatory contract-one that was dependent upon some fortuito...
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