Gulf Oil Corp. v. Commissioner
United States Tax Court
In 1971, Gulf incorporated Insco, a wholly owned foreign subsidiary, to conduct a general insurance business. During 1974 and 1975, Gulf and its affiliates insured risks with unrelated insurance carriers who, by prearrangement, reinsured with Insco and ceded premiums on such reinsurance to Insco. Insco paid claims on the reinsured risks. In 1975, Insco began insuring risks of unrelated parties.
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In 1971, Gulf incorporated Insco, a wholly owned foreign subsidiary, to conduct a general insurance business. During 1974 and 1975, Gulf and its affiliates insured risks with unrelated insurance carriers who, by prearrangement, reinsured with Insco and ceded premiums on such reinsurance to Insco. Insco paid claims on the reinsured risks. In 1975, Insco began insuring risks of unrelated parties. Net premium income from unrelated parties represented 2 percent of its total net premium income in 1975. The Commissioner determined that premium payments made by Gulf and its domestic affiliates were…
1Opinion of the Court
Gulf Oil Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Gulf Oil Corp. v. Commissioner
Docket No. 22499-82
United States Tax Court
89 T.C. 1010; 1987 U.S. Tax Ct. LEXIS 162; 89 T.C. No. 70;
November 24, 1987; As Amended November 30, 1987; As amended December 7, 1987 November 24, 1987, Filed
In 1971, Gulf incorporated Insco, a wholly owned foreign subsidiary, to conduct a general insurance business. During 1974 and 1975, Gulf and its affiliates insured risks with unrelated insurance carriers who, by prearrangement, reinsured with Insco and ceded premiums on such reinsurance…
Also in this document: Concurrence · Chabot; Concurrence · Nims; Dissent.
2Cases cited45 opinions
- Group Life & Health Insurance v. Royal Drug Co.Supreme Court of the United States · 1979
- Allen v. CommissionerUnited States Tax Court · 1979
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Benz v. CommissionerUnited States Tax Court · 1974
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