Legal Opinion

Allstate Fire Ins. Co. v. Commissioner

United States Tax Court

Decided December 2, 1966No. Docket No. 4812-64Published

Held, that petitioner, a casualty insurance company, may deduct the prorata portion of its investment expenses attributable to items of interest and dividends which are themselves deducted from gross income in computing taxable income.

1Opinion of the Court

Allstate Fire Insurance Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Allstate Fire Ins. Co. v. Commissioner

Docket No. 4812-64

United States Tax Court

47 T.C. 237; 1966 U.S. Tax Ct. LEXIS 13;

December 2, 1966, Filed

Decision will be entered under Rule 50.

Held, that petitioner, a casualty insurance company, may deduct the prorata portion of its investment expenses attributable to items of interest and dividends which are themselves deducted from gross income in computing taxable income.

Charles W. Davis, William A. Cromartie, and Lawrence M. Dubin, for the petitioner.

Nelson E.…

Also in this document: Concurrence.

2Cases cited10 opinions

  1. Commissioner v. BrownSupreme Court of the United States · 1965
  2. United States v. Atlas Life Insurance Co.Supreme Court of the United States · 1965
  3. Pink v. United StatesCourt of Appeals for the Second Circuit · 1939
  4. United States v. Home Title InsuranceSupreme Court of the United States · 1932
  5. Royal Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1938

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