Gulf Oil Corp. v. Commissioner
United States Tax Court
In 1971, Gulf incorporated Insco, a wholly owned foreign subsidiary, to conduct a general insurance business. During 1974 and 1975, Gulf and its affiliates insured risks with unrelated insurance carriers who, by prearrangement, reinsured with Insco and ceded premiums on such reinsurance to Insco. Insco paid claims on the reinsured risks. In 1975, Insco began insuring risks of unrelated parties.
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In 1971, Gulf incorporated Insco, a wholly owned foreign subsidiary, to conduct a general insurance business. During 1974 and 1975, Gulf and its affiliates insured risks with unrelated insurance carriers who, by prearrangement, reinsured with Insco and ceded premiums on such reinsurance to Insco. Insco paid claims on the reinsured risks. In 1975, Insco began insuring risks of unrelated parties. Net premium income from unrelated parties represented 2 percent of its total net premium income in 1975. The Commissioner determined that premium payments made by Gulf and its domestic affiliates were…
1Opinion of the Court
WHITAKER, Judge:*
The Commissioner determined deficiencies in petitioner’s Federal income tax for the taxable year 1974 in the amount of $80,813,428, and for the taxable year 1975 in the amount of $166,316,320. Petitioner, respondent, and the Court agreed that certain issues would be severed and tried at a special trial session.1 One of the issues tried was designated as the “Insco issue.” It involves the following two questions:(1) Whether petitioner may deduct as ordinary and necessary business expenses amounts paid as insurance premiums by Gulf Oil Corp. and its domestic affiliates to the…
2Cases cited29 opinions
- Group Life & Health Insurance v. Royal Drug Co.Supreme Court of the United States · 1979
- Allen v. CommissionerUnited States Tax Court · 1979
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Benz v. CommissionerUnited States Tax Court · 1974
24 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Gulf Oil Corporation, in No. 89-2049 v. Commissioner of Internal Revenue. Commissioner of Internal Revenue, in No. 89-2050 v. Gulf Oil CorporationCourt of Appeals for the Third Circuit · 1990
- Humana Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Amerco v. CommissionerUnited States Tax Court · 1991
- Sears, Roebuck and Co. And Affiliated Corporations, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1992
25 more not listed; retrieve them via the Exa API.