Royal Ins. Co. v. Commissioner
United States Board of Tax Appeals
Petitioner is a British corporation engaged, through a branch office, in the fire and marine insurance business in the United States. During 1928 and 1929, this branch office transferred, on its books, to the home office in England certain earnings from the business here.
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Petitioner is a British corporation engaged, through a branch office, in the fire and marine insurance business in the United States. During 1928 and 1929, this branch office transferred, on its books, to the home office in England certain earnings from the business here. Part of these funds, which were never transferred physically out of the United States but remained here subject to the control of the branch manager, were used by him to purchase stock in the Allied Securities Corporation, an American corporation. This stock was held in the United States by the branch office but recorded…
1Opinion of the Court
OPINION.
Leech:
This proceeding seeks redetermination of a deficiency in income tax of $54,551.90 for the calendar year, 1931. The petitioner denies the existence of a deficiency and asserts an overassessment of taxes for that year in the amount of $11,150.79.
There are three issues of law presented. The facts are not in dispute. For convenience, the issues will be decided in order and the facts, pertaining to each, set out thereunder.
*956 Issue No. 1.
The question in this issue is the deductibility of a loss of $630,-893.26, sustained by petitioner, in 1931, on the sale of certain investment…
2Cases cited1 opinion
- Biddle v. CommissionerSupreme Court of the United States · 1938
3Cited by13 opinions
- Motors Insurance v. United StatesUnited States Court of Claims · 1976
- Kronenberg v. CommissionerUnited States Tax Court · 1975
- Commercial Union Assur. Co. v. CommissionerCourt of Appeals for the Second Circuit · 1944
- United States v. Algemene Kunstzijde Unie, N. v. a Corporation Organized Under the Laws of the NetherlandsCourt of Appeals for the Fourth Circuit · 1955
- Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
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