Allied Fidelity Corp. v. Commissioner
United States Tax Court
AFIC was primarily engaged in the business of acting as surety on bail bonds. It also wrote fidelity, other surety, and automobile insurance contracts. In accordance with insurance accounting principles, AFIC excluded "unearned premiums" from income, deducted estimates of "unpaid net losses" and "unpaid loss adjustment expenses," and included in income declared but unpaid dividends on stock it held in unrelated corporations.
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AFIC was primarily engaged in the business of acting as surety on bail bonds. It also wrote fidelity, other surety, and automobile insurance contracts. In accordance with insurance accounting principles, AFIC excluded "unearned premiums" from income, deducted estimates of "unpaid net losses" and "unpaid loss adjustment expenses," and included in income declared but unpaid dividends on stock it held in unrelated corporations. Held, AFIC is not an insurance company taxable under secs. 831 and 832, I.R.C. 1954. Held, further, AFIC's method of accounting for "unearned premiums," "unpaid net…
1Opinion of the Court
Allied Fidelity Corporation f.k.a. William E. Roe, Allied Agents, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Allied Fidelity Corp. v. Commissioner
Docket No. 8676-74
United States Tax Court
66 T.C. 1068; 1976 U.S. Tax Ct. LEXIS 46;
September 27, 1976, Filed
Decision will be entered under Rule 155.
AFIC was primarily engaged in the business of acting as surety on bail bonds. It also wrote fidelity, other surety, and automobile insurance contracts. In accordance with insurance accounting principles, AFIC excluded "unearned premiums" from income, deducted estimates of "unpaid net…
2Cases cited46 opinions
- Stack v. BoyleSupreme Court of the United States · 1952
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Brown v. HelveringSupreme Court of the United States · 1934
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
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