Maryland Deposit Ins. Fund Corp. v. Commissioner
United States Tax Court
Petitioner's predecessor, Maryland Savings-Share Insurance Corp. (MSSIC), insured savings account deposits made with savings and loan associations chartered in the State of Maryland. For Federal income tax purposes, MSSIC claimed deductions for estimated "incurred but not reported" insurance losses for each of the years in issue. Held: MSSIC did not have any IBNR insurance losses during the years in issue. Petitioner therefore is not entitled to the deductions claimed.
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Petitioner's predecessor, Maryland Savings-Share Insurance Corp. (MSSIC), insured savings account deposits made with savings and loan associations chartered in the State of Maryland. For Federal income tax purposes, MSSIC claimed deductions for estimated "incurred but not reported" insurance losses for each of the years in issue. Held: MSSIC did not have any IBNR insurance losses during the years in issue. Petitioner therefore is not entitled to the deductions claimed. Sec. 832(b)(5), I.R.C. 1954.
1Opinion of the Court
State of Maryland Deposit Insurance Fund Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Maryland Deposit Ins. Fund Corp. v. Commissioner
Docket Nos. 26511-82, 34747-84
United States Tax Court
88 T.C. 1050; 1987 U.S. Tax Ct. LEXIS 59; 88 T.C. No. 59;
April 27, 1987. April 27, 1987, Filed
Decision will be entered under Rule 155.
Petitioner's predecessor, Maryland Savings-Share Insurance Corp. (MSSIC), insured savings account deposits made with savings and loan associations chartered in the State of Maryland. For Federal income tax purposes, MSSIC claimed deductions for…
2Cases cited12 opinions
- United States v. Maryland Savings-Share Ins. Corp.Supreme Court of the United States · 1970
- Powell v. RothensiesCourt of Appeals for the Third Circuit · 1950
- Hanover Insurance Company, Successor in Interest to Massachusetts Bonding and Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1979
- Hanover Ins. Co. v. CommissionerUnited States Tax Court · 1976
- Home Mutual Insurance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Seventh Circuit · 1980
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