Legal Opinion

Crawford Fitting Co. v. United States

District Court, N.D. Ohio

Decided January 16, 1985No. C82-3008PublishedCited by 15 opinions

1Opinion of the Court

MEMORANDUM OPINION

DOWD, District Judge.

This is an income tax refund suit brought by the taxpayer and plaintiff, Crawford Fitting Company, arising from the disallowance of an expense deduction to plaintiff of $20,485.00 for an “insurance premium” paid to a captive insurance company, the Constance Insurance Company. The disallowance of the deduction resulted in an income tax deficiency of $9,423.00 owed by the plaintiff to the defendant. Plaintiff contends that its payment of the insurance premium was deductible as an ordinary and necessary business expense under § 162(a) of the 1954 Internal…

2Cases cited13 opinions

  1. Eisner v. MacOmberSupreme Court of the United States · 1920
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Eisner, Internal Revenue Collector v. MacOmberSupreme Court of the United States · 1919
  4. Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
  5. Helvering v. Le GierseSupreme Court of the United States · 1941

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

3Cited by15 opinions

  1. Clougherty Packing Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  2. Beech Aircraft Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1986
  3. Gulf Oil Corp. v. CommissionerUnited States Tax Court · 1987
  4. Humana, Inc. v. CommissionerUnited States Tax Court · 1987
  5. Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API