Maryland Deposit Ins. Fund Corp. v. Commissioner
United States Tax Court
Petitioner's predecessor, Maryland Savings-Share Insurance Corp. (MSSIC), insured savings account deposits made with savings and loan associations chartered in the State of Maryland. For Federal income tax purposes, MSSIC claimed deductions for estimated "incurred but not reported" insurance losses for each of the years in issue. Held: MSSIC did not have any IBNR insurance losses during the years in issue. Petitioner therefore is not entitled to the deductions claimed.
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Petitioner's predecessor, Maryland Savings-Share Insurance Corp. (MSSIC), insured savings account deposits made with savings and loan associations chartered in the State of Maryland. For Federal income tax purposes, MSSIC claimed deductions for estimated "incurred but not reported" insurance losses for each of the years in issue. Held: MSSIC did not have any IBNR insurance losses during the years in issue. Petitioner therefore is not entitled to the deductions claimed. Sec. 832(b)(5), I.R.C. 1954.
1Opinion of the Court
SWIFT, Judge:
Petitioner State of Maryland Deposit Insurance Fund Corp. (MDIFC) is the successor corporation to Maryland Savings-Share Insurance Corp. (MSSIC). MDIFC is a nonstock, nonprofit corporation organized on May 18, 1985, by the State of Maryland to provide insurance to savings and loan associations chartered within the State. In early 1985, several savings and loan associations insured by MSSIC defaulted on their obligations. This created a crisis, within the savings and loan community in Maryland. MSSIC was merged into MDIFC, and all of the assets, liabilities, rights, powers,…
2Cases cited11 opinions
- United States v. Maryland Savings-Share Ins. Corp.Supreme Court of the United States · 1970
- Powell v. RothensiesCourt of Appeals for the Third Circuit · 1950
- Hanover Insurance Company, Successor in Interest to Massachusetts Bonding and Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1979
- Hanover Ins. Co. v. CommissionerUnited States Tax Court · 1976
- Home Mutual Insurance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Seventh Circuit · 1980
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