Sears, Roebuck & Co. v. Commissioner
United States Tax Court
P is the parent of three wholly owned insurance company subsidiaries, S1, S2, and S3. S1 was a casualty and liability insurer and issued policies to P. P's premium payments to S1 represented .25 of 1 percent of the total premiums earned by S1. S1 conducted business with P in the same manner as it did with unrelated insureds; insurance contracts were written, premiums transferred, and losses paid.
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P is the parent of three wholly owned insurance company subsidiaries, S1, S2, and S3. S1 was a casualty and liability insurer and issued policies to P. P's premium payments to S1 represented .25 of 1 percent of the total premiums earned by S1. S1 conducted business with P in the same manner as it did with unrelated insureds; insurance contracts were written, premiums transferred, and losses paid. On consolidated returns, S1 deducted reserves based on premiums received from P. S2 and S3 insured lenders against losses on mortgage loans. S2 and S3 did not pay a loss until the insured lender…
1Opinion of the Court
Sears, Roebuck and Co. and Affiliated Corporations, Petitioner v. Commissioner of Internal Revenue, Respondent
Sears, Roebuck & Co. v. Commissioner
Docket No. 2165-89
United States Tax Court
96 T.C. 61; 1991 U.S. Tax Ct. LEXIS 5; 96 T.C. No. 5;
January 24, 1991, Filed
Decision will be entered under Rule 155.
P is the parent of three wholly owned insurance company subsidiaries, S1, S2, and S3. S1 was a casualty and liability insurer and issued policies to P. P's premium payments to S1 represented .25 of 1 percent of the total premiums earned by S1. S1 conducted business with P in the same manner as…
Also in this document: Concurring in part, dissenting in part · Nims; Concurring in part, dissenting in part · Chabot; Dissent.
2Cases cited39 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Mid-State Fertilizer Co., Lasley Kimmel, and Maxine Kimmel v. Exchange National Bank of ChicagoCourt of Appeals for the Seventh Circuit · 1989
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