Legal Opinion

American Financial Corp. v. Commissioner

United States Tax Court

Decided June 14, 1979No. Docket No. 11559-77Published

Petitioner is the successor in interest to National General Co., which in turn was the successor in interest to Great American Holding Co. In various years prior to 1960, Great American Insurance Co., a subsidiary of Holding Co., paid insurance claims for which Holding Co. claimed a deduction for losses incurred pursuant to sec. 832(b)(5), I.R.C. 1954, on its consolidated return.

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Petitioner is the successor in interest to National General Co., which in turn was the successor in interest to Great American Holding Co. In various years prior to 1960, Great American Insurance Co., a subsidiary of Holding Co., paid insurance claims for which Holding Co. claimed a deduction for losses incurred pursuant to sec. 832(b)(5), I.R.C. 1954, on its consolidated return. These deductions did not result in any tax benefit to Holding Co. In 1966, Insurance Co. received salvage and subrogation proceeds with respect to the claims paid prior to 1960. Of the total salvage and subrogation…

1Opinion of the Court

American Financial Corporation (successor in interest to National General Corporation, the successor in interest to Great American Holding Company) and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

American Financial Corp. v. Commissioner

Docket No. 11559-77

United States Tax Court

72 T.C. 506; 1979 U.S. Tax Ct. LEXIS 101;

June 14, 1979, Filed

Decision will be entered under Rule 155.

Petitioner is the successor in interest to National General Co., which in turn was the successor in interest to Great American Holding Co. In various years prior to 1960, Great American…

2Cases cited13 opinions

  1. Phœnix Insurance v. Erie & Western Transportation Co.Supreme Court of the United States · 1886
  2. Farr v. CommissionerUnited States Tax Court · 1948
  3. Sloane v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1951
  4. Birmingham Terminal Co. v. CommissionerUnited States Tax Court · 1951
  5. Continental Insurance v. United StatesUnited States Court of Claims · 1973

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