Commercial Fishermen's Inter-Insurance Exchange v. Commissioner
United States Tax Court
Held: 1. An unincorporated mutual marine insurance association which keeps its books and files its Federal income tax returns on an accrual basis is entitled to deduct dividends declared in the year so declared to the extent of the indebtedness thus created to its policyholders even though a part of the dividend is contributed by such policyholder to the association for a recognized interest represented by such contribution, but is not entitled to deduct amounts withheld as…
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Held: 1. An unincorporated mutual marine insurance association which keeps its books and files its Federal income tax returns on an accrual basis is entitled to deduct dividends declared in the year so declared to the extent of the indebtedness thus created to its policyholders even though a part of the dividend is contributed by such policyholder to the association for a recognized interest represented by such contribution, but is not entitled to deduct amounts withheld as loss retentions under a preexisting resolution with no interest in such retention remaining in the policyholders. 2.…
1Opinion of the Court
Scott, Judge:
Respondent in his notice of deficiency determined deficiencies in petitioner’s income tax for the years and in the amounts as follows:
Year Deficiency
1952_$4,998.08
1953_ 21, 500. 66
1954_ 17, 086. 45
1955_ 48, 532.33
By amended, petition, petitioner alleged that it sustained a net operating loss for its taxable year 1957, thus becoming entitled to a net operating loss deduction for its taxable year 1955, and also claiming net operating loss carrybacks from 1955 and 1956 to 1953 and 1954. Respondent, by amendment to answer, alleged that the amount of excess profits credit carryover as…
2Cases cited13 opinions
- General American Investors Co. v. CommissionerSupreme Court of the United States · 1955
- Dallmeyer v. CommissionerUnited States Tax Court · 1950
- American Equitable Assur. Co. of New York v. HelveringCourt of Appeals for the Second Circuit · 1933
- Abraham Teitelbaum v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Order of R. Employees v. CommissionerUnited States Tax Court · 1943
8 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Weisbart v. CommissionerUnited States Tax Court · 1982
- Commercial Fishermen's Inter-Insurance Exchange v. CommissionerUnited States Tax Court · 1962
- Weisbart v. CommissionerUnited States Tax Court · 1982