Theodore v. Commissioner
United States Tax Court
1. National Mutual was organized as a mutual insurance company and during the taxable years in issue was doing business as such in the State in which it was organized.
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1. National Mutual was organized as a mutual insurance company and during the taxable years in issue was doing business as such in the State in which it was organized. The company's bylaws provided that each vehicle insured by the company qualified the member-owner thereof to one vote and further provided that in the event of dissolution or liquidation any balance or surplus remaining over and above all liabilities and expenses should be distributed to policyholders in proportion to their premium or assessment earned and paid to the company within 1 year immediately preceding the date of the…
1Opinion of the Court
Withey, Judge:
The respondent has determined deficiencies in the income tax of the petitioners as follows for the indicated years:
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Issues presented by the pleadings are tbe correctness of the respondent’s action:
In the Case of Peter Theodore.
In determining (1) that net income of National Mutual Casualty Company in the amounts of $34,948.33, $40,583.08, $40,657.13, and $40,633.50 for the years 1953, 1954, 1955, and 1957, respectively, was taxable to petitioner for the respective years, or (2) in the alternative, that of the amounts, $98,412.50, $114,296, $114,438, and $114,438,…
2Cases cited4 opinions
- Order of R. Employees v. CommissionerUnited States Tax Court · 1943
- Holyoke Mut. Fire Ins. Co. v. CommissionerUnited States Tax Court · 1957
- Mutual Fire, Marine & Inland Ins. Co. v. CommissionerUnited States Tax Court · 1947
- Estate of Moyer v. Comm'rUnited States Tax Court · 1959
3Cited by26 opinions
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Carnation Co. v. CommissionerUnited States Tax Court · 1978
- W. Larry Harlan and Mary Jane Harlan v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Chemplast, Inc. v. CommissionerUnited States Tax Court · 1973
- Modern Life & Acci. Ins. Co. v. CommissionerUnited States Tax Court · 1968
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