Houston Title Guaranty Co. v. Commissioner
United States Tax Court
Petitioner is a corporation organized under the laws of Texas and during the year 1949 was engaged in the title insurance business conducted as required by article 1302a of the Revised Civil Statutes of Texas and was subject to Federal income tax under the provisions of section 204 of the Internal Revenue Code.
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Petitioner is a corporation organized under the laws of Texas and during the year 1949 was engaged in the title insurance business conducted as required by article 1302a of the Revised Civil Statutes of Texas and was subject to Federal income tax under the provisions of section 204 of the Internal Revenue Code. Petitioner collected premiums on its title policies in 1949 of $ 162,875.34 and increased the credit balance in an account on its books entitled "Guaranty Loss Reserve" by 5 per cent of its premiums collected as required by section 10, article 1302a, Revised Civil Statutes of Texas. On…
1Opinion of the Court
opinion.
Black, Judge:
It is agreed by both parties that petitioner, during the taxable year 1949, was engaged in the title insurance business and was subject to Federal income tax under the provisions of section 204, Internal Revenue Code. The applicable portions of section 204 of the Code are printed in the margin.1
The question which we are called upon to decide is this: Is the total amount of premiums received in 1949 by petitioner, a title insurance company, includible in its gross income under section 204 without any exclusion or deduction therefrom for an addition made by it during that…
2Cases cited8 opinions
- Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
- American Title Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1935
- Wayne Title & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Commissioner v. Dallas Title & Guaranty Co.Court of Appeals for the Fifth Circuit · 1941
- Early v. Lawyers Title Ins. CorporationCourt of Appeals for the Fourth Circuit · 1942
3 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Washington Title Insurance v. United StatesUnited States Court of Claims · 1955
- Title & Trust Co. v. CommissionerUnited States Tax Court · 1972
- Houston Title Guaranty Co. v. CommissionerUnited States Tax Court · 1954
- Title & Trust Co. v. CommissionerUnited States Tax Court · 1972