City Title Ins. Co. v. Commissioner
United States Tax Court
Held, petitioner's reinsurance reserve in the amount of $27,701.25, accumulated from June 1, 1938 to May 31, 1945, is properly includible in computing the reinsurance reserve to be deducted from its underwriting income in the year 1945 since, pursuant to the New York Insurance Law, as amended, such sum constitutes unearned premiums within the meaning of section 204(b)(5) of the 1939 Code. Home Title Guaranty Co., 15 T.C. 637 (1950), followed.
1Opinion of the Court
City Title Insurance Company v. Commissioner.
City Title Ins. Co. v. Commissioner
Docket No. 49775.
United States Tax Court
T.C. Memo 1955-233; 1955 Tax Ct. Memo LEXIS 107; 14 T.C.M. (CCH) 939; T.C.M. (RIA) 55233;
August 19, 1955
Held, petitioner's reinsurance reserve in the amount of $27,701.25, accumulated from June 1, 1938 to May 31, 1945, is properly includible in computing the reinsurance reserve to be deducted from its underwriting income in the year 1945 since, pursuant to the New York Insurance Law, as amended, such sum constitutes unearned premiums within the meaning of section 204(b)(5)…
2Cases cited3 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
- Home Title Guaranty Co. v. CommissionerUnited States Tax Court · 1950