Buckeye Union Casualty Co. v. Commissioner
United States Tax Court
Petitioners, three affiliated casualty insurance companies, transferred their insurance businesses as going concerns to Buckeye Union Insurance Co., a newly formed corporation and wholly owned subsidiary of the Continental Insurance Co. The transfer was effected through two related agreements entitled "Reinsurance and Assumption Agreement" and "Supplemental Agreement" and resulted in an increase of $ 16,376,071.52 in the petitioners' net worth.
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Petitioners, three affiliated casualty insurance companies, transferred their insurance businesses as going concerns to Buckeye Union Insurance Co., a newly formed corporation and wholly owned subsidiary of the Continental Insurance Co. The transfer was effected through two related agreements entitled "Reinsurance and Assumption Agreement" and "Supplemental Agreement" and resulted in an increase of $ 16,376,071.52 in the petitioners' net worth. This increase consisted of $ 5,700,000 paid to petitioners for goodwill under the supplemental agreement and $ 10,676,071.52 retained by the…
1Opinion of the Court
The Buckeye Union Casualty Company and Subsidiary, Petitioners v. Commissioner of Internal Revenue, Respondent; The Buckeye Union Fire Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Buckeye Union Casualty Co. v. Commissioner
Docket Nos. 4997-67, 4998-67
United States Tax Court
54 T.C. 13; 1970 U.S. Tax Ct. LEXIS 234;
January 14, 1970, Filed
Decisions will be entered under Rule 50.
Petitioners, three affiliated casualty insurance companies, transferred their insurance businesses as going concerns to Buckeye Union Insurance Co., a newly formed corporation and wholly…
2Cases cited10 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Verito v. CommissionerUnited States Tax Court · 1965
- V. L. Phillips & Co., Inc. v. Pennsylvania Threshermen & Farmers' Mut. Cas. Ins. CoCourt of Appeals for the Fourth Circuit · 1952
- Massachusetts Fire & Marine Ins. Co. v. Com'r of Int. Rev.Court of Appeals for the Second Circuit · 1930
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