Legal Opinion

Allstate Fire Ins. Co. v. Commissioner

United States Tax Court

Decided December 2, 1966No. Docket No. 4812-64PublishedCited by 4 opinions

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

OPINION

Dawson, Judge:

Respondent determined deficiencies in petitioner’s income taxes for the years ended December 31,1958, and December 31, 1959, in the respective amounts of $149,433.51 and $34,158.79. Petitioner has claimed overpayments for the same years in the amounts of $90,269.61 and $26,771.48, respectively.

Certain adjustments were either uncontested or have been resolved by agreement of the parties. These will be given effect in the Rule 50 computation. The only issue presented for our decision is whether petitioner, a casualty insurance company, may deduct the prorata portion of its…

2Cases cited9 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

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

3Cited by4 opinions

  1. Continental Insurance Co. v. Secretario de HaciendaSupreme Court of Puerto Rico · 2001
  2. The Title Guarantee Company v. The United StatesUnited States Court of Claims · 1970
  3. Allstate Fire Ins. Co. v. CommissionerUnited States Tax Court · 1966
  4. Continental Insurance Company v. Secretario De HaciendaSupreme Court of Puerto Rico · 2001

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