Bay Counties Title Guaranty Co. v. Commissioner
United States Tax Court
Petitioner is an underwritten title and controlled escrow company engaged in the business of making abstracts of titles. It had an established title plant prior to 1952 which was its chief capital asset. Since petitioner started business it has followed the practice of acquiring for a consideration from others each year a substantial number of previously prepared title reports showing the status of titles to pieces of property up to some date prior to petitioner's purchase.
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Petitioner is an underwritten title and controlled escrow company engaged in the business of making abstracts of titles. It had an established title plant prior to 1952 which was its chief capital asset. Since petitioner started business it has followed the practice of acquiring for a consideration from others each year a substantial number of previously prepared title reports showing the status of titles to pieces of property up to some date prior to petitioner's purchase. Most of such title reports were filed in petitioner's records for use in subsequent years depending on when the…
1Opinion of the Court
OPINION'.
HaeRON, Judge:
The issue relates to the matter of the proper treatment for tax purposes of an expense which petitioner incurs and pays in cash each year to real estate brokers, chiefly, for preliminary title reports and copies of noncurrent title insurance policies which have been prepared and used previously by others in the same business. For convenience such material is described hereinafter, collectively, as starter reports.
It is understood that for the most part each of the starter reports acquired deals with the status of the title to an individual and different piece of real…
2Cases cited10 opinions
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- Consolidated Apparel Co. v. CommissionerUnited States Tax Court · 1952
- Consolidated Apparel Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1953
- Russell Box Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953
- Appeal of First National Bank of St. LouisUnited States Board of Tax Appeals · 1926
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3Cited by1 opinion
- Bay Counties Title Guaranty Co. v. CommissionerUnited States Tax Court · 1960