Legal Opinion

Houston Title Guaranty Co. v. Commissioner

United States Tax Court

Decided July 30, 1954No. Docket No. 48482Published

Petitioner is a corporation organized under the laws of Texas and during the year 1949 was engaged in the title insurance business conducted as required by article 1302a of the Revised Civil Statutes of Texas and was subject to Federal income tax under the provisions of section 204 of the Internal Revenue Code.

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Petitioner is a corporation organized under the laws of Texas and during the year 1949 was engaged in the title insurance business conducted as required by article 1302a of the Revised Civil Statutes of Texas and was subject to Federal income tax under the provisions of section 204 of the Internal Revenue Code. Petitioner collected premiums on its title policies in 1949 of $ 162,875.34 and increased the credit balance in an account on its books entitled "Guaranty Loss Reserve" by 5 per cent of its premiums collected as required by section 10, article 1302a, Revised Civil Statutes of Texas. On…

1Opinion of the Court

Houston Title Guaranty Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Houston Title Guaranty Co. v. Commissioner

Docket No. 48482

United States Tax Court

22 T.C. 989; 1954 U.S. Tax Ct. LEXIS 131;

July 30, 1954, Filed July 30, 1954, Filed

Decision will be entered for the respondent.

Petitioner is a corporation organized under the laws of Texas and during the year 1949 was engaged in the title insurance business conducted as required by article 1302a of the Revised Civil Statutes of Texas and was subject to Federal income tax under the provisions of section 204 of the Internal…

2Cases cited9 opinions

  1. Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
  2. American Title Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1935
  3. Wayne Title & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
  4. Commissioner v. Dallas Title & Guaranty Co.Court of Appeals for the Fifth Circuit · 1941
  5. Early v. Lawyers Title Ins. CorporationCourt of Appeals for the Fourth Circuit · 1942

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