Legal Opinion
Royal Indemnity Co. v. Tax Appeals Tribunal
New York Court of Appeals
Decided December 21, 1989PublishedCited by 9 opinions
1Opinion of the Court
OPINION OF THE COURT
Hancock, Jr., J.
We agree with the Appellate Division that under Tax Law § 1503 (b) (4) (B) a taxpayer’s State deduction for net operating losses for a tax year is limited to the amount of the Federal loss deduction for the same year.
The facts are not in dispute. Petitioner, a property and casualty insurer, is a Delaware corporation licensed to do business in New York. For tax years beginning on or after January 1, 1974, petitioner became subject to tax under article 33 of the Tax Law (Tax Law § 1500 et seq.) for the privilege of doing business in this State (see, Tax Law §…
2Cases cited6 opinions
- Grace v. New York State Tax CommissionNew York Court of Appeals · 1975
- Straus v. TullyNew York Court of Appeals · 1979
- American Employers' Insurance v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1985
- MATTER OF GURNEY v. TullyNew York Court of Appeals · 1980
- Eveready Insurance v. New York State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1987
1 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Aetna Casualty & Surety Co. v. Tax Appeals TribunalAppellate Division of the Supreme Court of the State of New York · 1995
- Somerset Telephone Company v. State Tax AssessorSupreme Judicial Court of Maine · 2021
- Citrin Cooperman & Co. v. Tax Appeals TribunalAppellate Division of the Supreme Court of the State of New York · 2008
- Horowitz v. New York City Tax Appeals TribunalAppellate Division of the Supreme Court of the State of New York · 2007
- Matter of Ciardullo v. McDonnellAppellate Division of the Supreme Court of the State of New York · 2025
4 more not listed; retrieve them via the Exa API.