Pacific Employers Ins. Co. v. Commissioner
United States Board of Tax Appeals
As the Revenue Act of 1928 does not allow deductions for reserves to insurance companies other than life or mutual, a company writing workmen's compensation and liability insurance may not take as a deduction for "unpaid losses" a reserve based on the amount of premiums. The deduction allowable is the amount computed as its probable liability on claims filed.
1Opinion of the Court
opinion.
ARUndell :
The respondent determined a deficiency in petitioner’s income tax for the year 1930 in the amount of $1,193.45. Upon waiver by petitioner of several alleged errors there is presented but one issue for decision, namely,, the amount allowable as a deduction for “losses incurred” within the meaning of section 204(b) (6) of the Revenue Act of 1928. The parties have stipulated that, if the method of computing the amount allowable now advocated by petitioner is proper, there is an overpayment of $1,212.24, otherwise the deficiency determined by the respondent is correct.
The facts…
2Cited by10 opinions
- Commissioner of Internal Revenue v. General Reinsurance CorpCourt of Appeals for the Second Circuit · 1951
- Harco Holdings, Incorporated, and Subsidiaries v. United StatesCourt of Appeals for the Seventh Circuit · 1992
- Central Reserve Life Corp. v. CommissionerUnited States Tax Court · 1999
- Modern Home Life Ins. Co. v. CommissionerUnited States Tax Court · 1970
- Columbia Cas. Co. v. CommissionerUnited States Tax Court · 1948
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