American Title Co. v. Commissioner
United States Board of Tax Appeals
1. Premiums paid a title insurance company for policies guaranteeing land titles are earned when paid and constitute gross income. 2. A reserve set up to meet future liabilities under title insurance policies is not deductible from gross income. 3. Quaere: Whether reserves set up to meet future liabilities under title insurance policies pursuant to Act No. 362, Laws of Pennsylvania, 1929, are "reserves required by law" within the meaning of the Revenue Act of 1928.
1Opinion of the Court
AMERICAN TITLE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
American Title Co. v. Commissioner
Docket No. 61461.
United States Board of Tax Appeals
29 B.T.A. 479; 1933 BTA LEXIS 937;
November 29, 1933, Promulgated
1. Premiums paid a title insurance company for policies guaranteeing land titles are earned when paid and constitute gross income.
2. A reserve set up to meet future liabilities under title insurance policies is not deductible from gross income.
3. Quaere: Whether reserves set up to meet future liabilities under title insurance policies pursuant to Act No. 362, Laws…
2Cases cited12 opinions
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
- United States v. Henry Prentiss & Co.Supreme Court of the United States · 1933
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- Bowers v. Lawyers Mortgage Co.Supreme Court of the United States · 1932
- United States v. Boston InsuranceSupreme Court of the United States · 1925
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