Oklahoma State Union of Farmers Educational & Cooperative Union v. Commissioner
United States Tax Court
Held, petitioner is a mutual insurance company under sec. 821(a) and is taxable as such.
1Opinion of the Court
Irwin, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income tax:
Year Deficiency
1970. $312,290.59
1971. 40,305.19
After a concession by petitioner regarding a short-term capital gain, the only issue remaining is whether petitioner was a mutual insurance company entitled to report its income pursuant to sections 821 through 826.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.
The petitioner, Oklahoma State Union of the Farmers…
2Cases cited13 opinions
- Theodore v. CommissionerUnited States Tax Court · 1962
- Order of R. Employees v. CommissionerUnited States Tax Court · 1943
- Holyoke Mut. Fire Ins. Co. v. CommissionerUnited States Tax Court · 1957
- Hanover Ins. Co. v. CommissionerUnited States Tax Court · 1976
- Mutual Fire, Marine & Inland Ins. Co. v. CommissionerUnited States Tax Court · 1947
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Avrahami v. Comm'rUnited States Tax Court · 2017
- Oklahoma State Union of Farmers Educational & Cooperative Union v. CommissionerUnited States Tax Court · 1977