Gerling Int'l Ins. Co. v. Commissioner
United States Tax Court
P reinsured a portion of the casualty insurance business of a Swiss company and received annual statements from that company in respect of the premium income, losses, and expenses of that business. In its Federal income tax returns, P included the data reflected in those statements. R adopted the premium income figures but disallowed the losses and expenses in their entirety.
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P reinsured a portion of the casualty insurance business of a Swiss company and received annual statements from that company in respect of the premium income, losses, and expenses of that business. In its Federal income tax returns, P included the data reflected in those statements. R adopted the premium income figures but disallowed the losses and expenses in their entirety. Held, under sec. 832, I.R.C., P is required to report and prove the gross figures shown on the Swiss company's statements and not simply the net amount of income or loss. Held, further, the statements are admissible in…
1Opinion of the Court
TANNENWALD, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $885 for the taxable year ending December 31, 1974, $2,043 for the taxable year ending December 31, 1975, $1,439,676 for the taxable year ending December 31, 1976, $1,917,174 for the taxable year ending December 31,1977, and $2,503,934 for the taxable year ending December 31, 1978. The issues for decision are: (1) Whether petitioner should be required, under section 832,1 to include in gross income its share of the underwriting income of Universale Reinsurance Co., Ltd., of Zurich, Switzerland…
2Cases cited37 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Societe Internationale Pour Participations Industrielles Et Commerciales, S. A. v. RogersSupreme Court of the United States · 1958
- Burnet v. HoustonSupreme Court of the United States · 1931
- United States v. Moreno L. Keplinger, Paul L. Wright, and James B. PlankCourt of Appeals for the Seventh Circuit · 1985
- In Re Korean Air Lines Disaster of September 1, 1983, Korean Air Lines Company, Ltd.Court of Appeals for the D.C. Circuit · 1991
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