Title & Trust Co. v. United States

McRAE, District Judge.

The issue in this action comes before the Court on cross-motions for summary judgment. The sole issue is whether the taxpayer, the plaintiff-corporation, may exclude or deduct from its taxable income the “reserve for unearned income” which it established pursuant to the laws of the State of Florida. All relevant facts have been presented by affidavit and the Government’s Requests for Admissions.

The taxpayer is a title insurance corporation organized under the laws of the State of Florida to engage in the business of insuring titles to real property in that state and was…