Modern Home Fire & Casualty Ins. Co. v. Commissioner
United States Tax Court
1. Held, that petitioner was not entitled to deduct or exclude 15 percent of the premiums received on title insurance as "unearned premiums" within the meaning of sec. 832(b)(4), I.R.C. 1954. 2. Held, that claims paid by petitioner pursuant to policies of title insurance were properly deducted as "losses incurred during the taxable year on insurance contracts" within the meaning of sec. 832(b) (5), I.R.C. 1954. 3. Held, that petitioner was entitled to the surtax exemption as…
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1. Held, that petitioner was not entitled to deduct or exclude 15 percent of the premiums received on title insurance as "unearned premiums" within the meaning of sec. 832(b)(4), I.R.C. 1954. 2. Held, that claims paid by petitioner pursuant to policies of title insurance were properly deducted as "losses incurred during the taxable year on insurance contracts" within the meaning of sec. 832(b) (5), I.R.C. 1954. 3. Held, that petitioner was entitled to the surtax exemption as provided in sec. 11(c), I.R.C. 1954, for the years in issue.
1Opinion of the Court
Modern Home Fire and Casualty Insurance Company, Petitioner 1 v. Commissioner of Internal Revenue, Respondent
Modern Home Fire & Casualty Ins. Co. v. Commissioner
Docket No. 1379-68
United States Tax Court
54 T.C. 839; 1970 U.S. Tax Ct. LEXIS 157;
April 23, 1970, Filed
Decision will be entered under Rule 50.
1. Held, that petitioner was not entitled to deduct or exclude 15 percent of the premiums received on title insurance as "unearned premiums" within the meaning of sec. 832(b)(4), I.R.C. 1954.
2. Held, that claims paid by petitioner pursuant to policies of title insurance were properly deducted as…
2Cases cited13 opinions
- Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
- Alinco Life Insurance Company v. The United StatesUnited States Court of Claims · 1967
- Bush Hog Mfg. Co. v. CommissionerUnited States Tax Court · 1964
- A. P. Green Export Company v. United StatesUnited States Court of Claims · 1960
- Barber-Greene Americas, Inc. v. CommissionerUnited States Tax Court · 1960
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