Legal Opinion

Hanover Ins. Co. v. Commissioner

United States Tax Court

Decided January 7, 1976No. Docket No. 1557-71PublishedCited by 19 opinions

Petitioner's predecessor, a casualty insurance company, reflected its income on its returns substantially on the basis of the underwriting exhibit of the annual statement approved by the National Association of Insurance Commissioners.

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Petitioner's predecessor, a casualty insurance company, reflected its income on its returns substantially on the basis of the underwriting exhibit of the annual statement approved by the National Association of Insurance Commissioners. Respondent adjusted the estimated figures for "unpaid losses" and "expenses unpaid," as shown on such returns and underwriting exhibit, under the "fair and reasonable estimate" test embodied in the predecessor to sec. 1.832-4(b), Income Tax Regs. Petitioner sought summary judgment on the grounds that sec. 832(b)(1), I.R.C. 1954, automatically precludes…

1Opinion of the Court

OPINION

Dawson, Chief Judge:

This case was assigned to Special Trial Judge Lehman C. Aarons (pursuant to Rule 180 et seq. of the Tax Court Rules of Practice and Procedure) to conduct the trial thereof or otherwise proceed in accordance with said Rules. This Court agrees with and adopts his opinion, set forth below, on petitioner’s Motion for Summary Judgment.1

OPINION OF THE SPECIAL TRIAL JUDGE

Aarons, Special Trial Judge:

This case is presently before the Court on petitioner’s Motion for Summary Judgment, filed September 8, 1975. Because of the importance of the legal question involved, the Court…

2Cases cited27 opinions

  1. Flint v. Stone Tracy Co.Supreme Court of the United States · 1911
  2. United States v. South-Eastern Underwriters Assn.Supreme Court of the United States · 1944
  3. Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
  4. Steward MacHine Co. v. DavisSupreme Court of the United States · 1937
  5. United States v. CorrellSupreme Court of the United States · 1967

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

3Cited by19 opinions

  1. Lantz v. Comm'rUnited States Tax Court · 2009
  2. Allied Fidelity Corp. v. CommissionerUnited States Tax Court · 1976
  3. Hanover Insurance Company, Successor in Interest to Massachusetts Bonding and Insurance Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1979
  4. Western Casualty & Surety Co. v. CommissionerUnited States Tax Court · 1976
  5. Home Mutual Insurance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Seventh Circuit · 1980

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

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