Legal Opinion

Paratransit Ins. Corp. v. Commissioner

United States Tax Court

Decided June 14, 1994No. Docket No. 28342-91XPublished

P is a California nonprofit mutual benefit insurance corporation. It provides automobile liability insurance to its members, all of which are tax-exempt social service organizations that furnish transportation to the elderly, the handicapped, the needy, etc.

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P is a California nonprofit mutual benefit insurance corporation. It provides automobile liability insurance to its members, all of which are tax-exempt social service organizations that furnish transportation to the elderly, the handicapped, the needy, etc. The premiums paid by a member for such insurance are determined actuarially to take into account a number of factors, such as the deductibles selected by the member, the number of vehicles used by the member, the number of passengers carried by each vehicle, and the radius of the member's operations. 1. Held, P is not exempt under sec.…

1Opinion of the Court

Paratransit Insurance Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Paratransit Ins. Corp. v. Commissioner

Docket No. 28342-91X

United States Tax Court

102 T.C. 745; 1994 U.S. Tax Ct. LEXIS 37; 102 T.C. No. 34;

June 14, 1994, Filed

Decision will be entered for respondent.

P is a California nonprofit mutual benefit insurance corporation. It provides automobile liability insurance to its members, all of which are tax-exempt social service organizations that furnish transportation to the elderly, the handicapped, the needy, etc. The premiums paid by a member for such insurance…

2Cases cited6 opinions

  1. Helvering v. Oregon Mutual Life InsuranceSupreme Court of the United States · 1940
  2. Murray Seasongood and Agnes Seasongood v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1955
  3. Haswell v. United StatesUnited States Court of Claims · 1974
  4. Mutual Aid Association of the Church of the Brethren v. United StatesCourt of Appeals for the Tenth Circuit · 1985
  5. Paratransit Ins. Corp. v. CommissionerUnited States Tax Court · 1994

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