American Title Co. v. Commissioner
United States Board of Tax Appeals
1. Premiums paid a title insurance company for policies guaranteeing land titles are earned when paid and constitute gross income. 2. A reserve set up to meet future liabilities under title insurance policies is not deductible from gross income. 3. Quaere: Whether reserves set up to meet future liabilities under title insurance policies pursuant to Act No. 362, Laws of Pennsylvania, 1929, are "reserves required by law" within the meaning of the Revenue Act of 1928.
1Opinion of the Court
*480OPINION.
Stbenhagen:
Soon after its organization in 1929 petitioner assumed all the title insurance liabilities of the American Bank & Trust Co. by the issuance of a formal policy of insurance, for which it was paid a fee of $25,000. It included the full amount of this fee, *481together with $445.90, representing 10 percent of other premiums on policies written in 1929, in a reserve, the whole amount of which, it contends, should be excluded or deducted from its gross income.
1. In guaranteeing land titles for a consideration, petitioner was engaged in an insurance business within the meaning of the…
2Cases cited11 opinions
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
- McCoach v. Insurance Co. of North AmericaSupreme Court of the United States · 1917
- Bowers v. Lawyers Mortgage Co.Supreme Court of the United States · 1932
- United States v. Boston InsuranceSupreme Court of the United States · 1925
- United States v. Home Title InsuranceSupreme Court of the United States · 1932
6 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Massachusetts Protective Ass'n v. United StatesCourt of Appeals for the First Circuit · 1940
- Commissioner of Internal Revenue v. General Reinsurance CorpCourt of Appeals for the Second Circuit · 1951
- Wayne Title & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1952
- Title & Trust Co. v. United StatesDistrict Court, M.D. Florida · 1965
- Sebring v. CommissionerUnited States Tax Court · 1989
5 more not listed; retrieve them via the Exa API.