Home Group v. Commissioner
United States Tax Court
P, in the process of appealing from a decision of this Court, filed an appeal bond for purposes of staying assessment and collection of P's affiliated and consolidated group's redetermined tax deficiency.
Read the full summary
P, in the process of appealing from a decision of this Court, filed an appeal bond for purposes of staying assessment and collection of P's affiliated and consolidated group's redetermined tax deficiency. Sec. 7485(a), I.R.C. 1986. The bond was issued by S, which is otherwise properly authorized as a surety under 31 U.S.C. sec. 9304 (1982). S is also a subsidiary of P and a member of the affiliated group that filed consolidated returns and, as such, is responsible for any finally determined tax deficiency. R objects to the use of S's bond on the ground that it does not represent adequate…
1Opinion of the Court
OPINION
Gerber, Judge:
This matter is before the Court on respondent’s motion to set aside our approval of petitioner’s appeal bond. On January 15, 1987, we held that Home Insurance Co. (sometimes referred to as Home) and Home Indemnity Co. (Indemnity), members of the consolidated group of corporations of which City Investing Co. was the common parent, were not entitled to deductions for insurance sales commissions associated with deferred and unearned insurance premiums.1 City Investing Co. v. Commissioner, T.C. Memo. 1987-36. In a second opinion we considered disputes arising from differences…
2Cases cited20 opinions
- National Union of Marine Cooks & Stewards v. ArnoldSupreme Court of the United States · 1954
- In the Matter of Yale Express System, Inc., Debtor. Boston Insurance Company v. F. Ralph Nogg, TrusteeCourt of Appeals for the Second Circuit · 1966
- Redding & Company, Inc. v. Russwine Construction CorporationCourt of Appeals for the D.C. Circuit · 1969
- Home Group v. CommissionerUnited States Tax Court · 1988
- Concord Casualty & Surety Co. v. United StatesCourt of Appeals for the Second Circuit · 1934
15 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Centex Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2005
- Centex Corp. v. United StatesUnited States Court of Federal Claims · 2003
- Pollei v. CommissionerUnited States Tax Court · 1990
- Kanofsky v. Comm'rUnited States Tax Court · 2010
- Home Group v. CommissionerUnited States Tax Court · 1989
1 more not listed; retrieve them via the Exa API.