Legal Opinion

Amerco v. Commissioner

United States Tax Court

Decided January 24, 1991No. Docket Nos. 5100-88, 4330-89PublishedCited by 36 opinions

P1 is an affiliated group of corporations that filed consolidated returns for the years at issue. P2 is a third-tier, wholly owned subsidiary of the parent of the P1 group. P2 did not participate in P1's consolidated returns. P2 is a fully licensed property and casualty insurance company. P1 purchased insurance from P2. Unrelated insureds purchased insurance from P2. Unrelated insureds comprised over 50 percent of P2's business during each of the years at issue.

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P1 is an affiliated group of corporations that filed consolidated returns for the years at issue. P2 is a third-tier, wholly owned subsidiary of the parent of the P1 group. P2 did not participate in P1's consolidated returns. P2 is a fully licensed property and casualty insurance company. P1 purchased insurance from P2. Unrelated insureds purchased insurance from P2. Unrelated insureds comprised over 50 percent of P2's business during each of the years at issue. R determined deficiencies against P1 and P2, based upon a disregard of the form of certain of P2's insurance transactions. Held, all…

1Opinion of the Court

KÓRNER, Judge:

By notices of deficiency, respondent determined the following deficiencies in petitioners’ Federal income tax;

AMERCO & Subsidiaries — Docket Nos. 5100-88 and 4380-89

TYE2 Deficiency

3/31/75.:.$1,152,077

4/02/77 . 1,173,053

4/01/78 . 4,055,392

3/31/79 . 7,928,408

3/29/80 . 13,252,182

4/03/82 . 763,623

4/02/83 . 10,960,156

3/31/84 . 4,416,580

3/30/85 . 645,671

Republic Western Insurance Co. — Docket No. 5100-88

TYE Deficiency

12/31/79 $9,960,885

12/31/80 570,141

12/31/81 .<■ 138,105

12/31/82 570,441

By an amendment to answer in docket No. 5100-88, respondent increased the deficiencies by the…

2Cases cited18 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  4. Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
  5. Helvering v. Le GierseSupreme Court of the United States · 1941

13 more not listed; retrieve them via the Exa API.

3Cited by36 opinions

  1. Cluck v. CommissionerUnited States Tax Court · 1995
  2. Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
  3. Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1992
  4. Amerco, Inc. Republic Insurance v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
  5. Harper Group v. CommissionerUnited States Tax Court · 1991

31 more not listed; retrieve them via the Exa API.

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