Policy Holders Agency, Inc. v. Commissioner
United States Tax Court
Where the constant experience of an accrual basis taxpayer, extending over 16 years, was that no claim against or payment out of a designated liability account had been made, held, that the yearly transfers to such account are determinative of income accrual rather than the subsequent transfer of the entire account to surplus.
1Opinion of the Court
OPINION
Forrester, Judge:
Respondent has determined a deficiency of $1,217.121 in petitioner’s income tax for the calendar year 1958. The only issue before us is whether petitioner realized taxable income in 1958 based on the transfer of unclaimed premium refunds from a liability account to a surplus account.
All of the facts have been stipulated and are so found.
The petitioner, Policy Holders Agency, Inc., hereinafter sometimes referred to as the petitioner, is a corporation organized and existing under the laws of the State of North Carolina. The petitioner is engaged in the business of…
2Cases cited27 opinions
- Commissioner v. HansenSupreme Court of the United States · 1959
- Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
- Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
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3Cited by13 opinions
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Bear Manufacturing Company v. United StatesCourt of Appeals for the Seventh Circuit · 1970
- Ryan v. CommissionerUnited States Tax Court · 1964
- Miller v. CommissionerUnited States Tax Court · 1981
- Estate of Bankhead v. CommissionerUnited States Tax Court · 1973
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