Commercial Union Assurance Co. v. Commissioner
United States Tax Court
Petitioner, a foreign insurance company doing business in the United States (other than life or mutual) incurred British income taxes and business expense at its London office, connected with income from sources within the United States, but not definitely allocable thereto.
Read the full summary
Petitioner, a foreign insurance company doing business in the United States (other than life or mutual) incurred British income taxes and business expense at its London office, connected with income from sources within the United States, but not definitely allocable thereto. Held, that in arriving at the ratio between total income and income from sources within the United States, in determining the deduction, the Commissioner did not err in excluding nontaxable interest and 85 percent of dividends from domestic corporations for which credit had been allowed; held, further, that, where…
1Opinion of the Court
OPINION.
Disney, Judge:
These cases, duly consolidated, involve deficiencies determined in income taxes and alleged overpayments claimed as follows:
[[Image here]]
The questions presented (identical as to each year) involve the deductibility by a foreign insurance company of business expenses., interest paid, and income taxes paid to a foreign country. The facts were stipulated in writing, a separate stipulation being filed for each of the taxable years. They are, however, identical, except for the figures contained. In material part the stipulation for the year 1938 (and for 1939, except for the…
2Cases cited2 opinions
- Helvering v. Ohio Leather Co.Supreme Court of the United States · 1942
- Wheeler v. CommissionerUnited States Tax Court · 1943
3Cited by8 opinions
- Commercial Union Assur. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1944
- Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
- Commercial Union Assur. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1945
- The Title Guarantee Company v. The United StatesUnited States Court of Claims · 1970
- Palatine Ins. Co. v. CommissionerUnited States Tax Court · 1944
3 more not listed; retrieve them via the Exa API.