Bituminous Casualty Corp. v. Commissioner
United States Tax Court
Held: 1. Bituminous Casualty Corp. correctly included in unearned premiums, as defined in sec. 832(b)(4), I.R.C. 1954, its reserves for retrospective rate credits and premium discount as reflected in its Annual Statements in the form approved by the National Convention of Insurance Commissioners.
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Held: 1. Bituminous Casualty Corp. correctly included in unearned premiums, as defined in sec. 832(b)(4), I.R.C. 1954, its reserves for retrospective rate credits and premium discount as reflected in its Annual Statements in the form approved by the National Convention of Insurance Commissioners. Such reserves were reasonable estimates of the portions of premiums otherwise "earned" at the end of each taxable year which it would be required to return to policyholders pursuant to its retrospective rating and premium discount policies. 2. Both the Casualty Corp. and the Fire & Marine Co.…
1Opinion of the Court
Dawson, Judge:
In these consolidated cases respondent determined the following Federal income tax deficiencies against the petitioners:
Bituminous Casualty Coep.
Docket No. 2610-69
Taxable year Amount
1958 _ $376, 583.11
1959_ 3, 625,228.02
1963_ 896, 973. 96
1964_ . 378, 905.39
Bituminous Fire & Marine Insur-
ance Co., Docket No. 2611-69
Taxable year Amount
1962_ $239,430. 71
1963 _ 51,123. 37
1964-68, 341. 74
1965 - 34, 851.48
Several issues involved in these cases have been resolved by agreement of the parties. The three issues presented for our decision are:(1) Did Bituminous Casualty Corp. properly…
2Cases cited9 opinions
- Country Mutual Insurance v. KnightIllinois Supreme Court · 1968
- Commissioner of Int. Rev. v. New Hampshire Fire Ins. Co.Court of Appeals for the First Circuit · 1945
- Fort Pitt Brewing Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
- Massachusetts Protective Ass'n v. United StatesCourt of Appeals for the First Circuit · 1940
- Fidelity-Philadelphia Trust Co. v. CommissionerUnited States Tax Court · 1954
4 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Gerling International Insurance Co. v. Commissioner of Internal Revenue. Appeal of Gerling International Insurance CoCourt of Appeals for the Third Circuit · 1988
- Sears, Roebuck & Co. v. CommissionerUnited States Tax Court · 1991
- Hanover Ins. Co. v. CommissionerUnited States Tax Court · 1976
- Lincoln National Life Insurance v. United StatesUnited States Court of Claims · 1978
- Western Casualty & Surety Co. v. CommissionerUnited States Tax Court · 1976
22 more not listed; retrieve them via the Exa API.