National Capital Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. The petitioner, an insurance company other than a life or mutual, reinsured a portion of each risk assumed, and received from the reinsurer so-called flat commissions based upon the net premiums of the insurance ceded to it and an additional amount, designated as "contingent commissions", based upon the net results of the reinsurance.
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1. The petitioner, an insurance company other than a life or mutual, reinsured a portion of each risk assumed, and received from the reinsurer so-called flat commissions based upon the net premiums of the insurance ceded to it and an additional amount, designated as "contingent commissions", based upon the net results of the reinsurance. Held, that the amounts are taxable income, being reimbursement for commissions paid by the petitioner to its agents on the reinsurance or an offset against premiums on the reinsurance. 2. Commissions received by the petitioner for acting as broker in the…
1Opinion of the Court
NATIONAL CAPITAL INSURANCE COMPANY OF THE DISTRICT OF COLUMBIA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
National Capital Ins. Co. v. Commissioner
Docket No. 56748.
United States Board of Tax Appeals
28 B.T.A. 1079; 1933 BTA LEXIS 1049;
August 15, 1933, Promulgated
1. The petitioner, an insurance company other than a life or mutual, reinsured a portion of each risk assumed, and received from the reinsurer so-called flat commissions based upon the net premiums of the insurance ceded to it and an additional amount, designated as "contingent commissions", based upon the net results…
2Cases cited1 opinion
- National Capital Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933