Amerco v. Commissioner
United States Tax Court
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
- Gregory v. HelveringSupreme Court of the United States · 1935
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Helvering v. Le GierseSupreme Court of the United States · 1941
13 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Cluck v. CommissionerUnited States Tax Court · 1995
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1992
- Amerco, Inc. Republic Insurance v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Harper Group v. CommissionerUnited States Tax Court · 1991
31 more not listed; retrieve them via the Exa API.