Legal Opinion

Commissioner of Internal Revenue v. General Reinsurance Corp

Court of Appeals for the Second Circuit

Decided June 20, 1951No. 21837_1PublishedCited by 18 opinions

1Opinion of the Court

CHASE, Circuit Judge.

The respondent is a stock casualty and surety company and as such is taxed upon its income pursuant to the provisions of § 204 of the Internal Revenue Code, 26 U.S.C.A. § 204. It is a New York corporation having its principal office in the City of New York and it filed its income tax returns with the Collector for the Second District of New York. In so doing it computed its net taxable income in strict accordance with what was reflected as such on the so-called “Convention Form” which is referred to in subsection (b) (1) of § 204, I. R. C. as “the underwriting and…

2Cases cited10 opinions

  1. Commissioner of Int. Rev. v. New Hampshire Fire Ins. Co.Court of Appeals for the First Circuit · 1945
  2. American Title Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1935
  3. Pacific Employers Ins. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1937
  4. New Hampshire Fire Ins. Co. v. CommissionerUnited States Tax Court · 1943
  5. United States v. Fidelity & Deposit Co.Court of Appeals for the Fourth Circuit · 1949

5 more not listed; retrieve them via the Exa API.

3Cited by18 opinions

  1. Gerling International Insurance Co. v. Commissioner of Internal Revenue. Appeal of Gerling International Insurance CoCourt of Appeals for the Third Circuit · 1988
  2. Bituminous Casualty Corp. v. CommissionerUnited States Tax Court · 1971
  3. Hanover Ins. Co. v. CommissionerUnited States Tax Court · 1976
  4. Western Casualty & Surety Co. v. CommissionerUnited States Tax Court · 1976
  5. Continental Insurance v. United StatesUnited States Court of Claims · 1973

13 more not listed; retrieve them via the Exa API.

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