More v. Commissioner
United States Tax Court
P is an individual underwriter for Lloyd's of London (Lloyd's). As an underwriter, P is required to demonstrate that he can cover potential losses on the policies that he underwrites, a.k.a., show means. In order to show means, P posted a letter of credit issued by Bank Julius Baer (BJB) with Lloyd's. The letter of credit was secured by P's preexisting stock portfolio. The policies that P underwrote for the taxable years 1992 and 1993 incurred losses.
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P is an individual underwriter for Lloyd's of London (Lloyd's). As an underwriter, P is required to demonstrate that he can cover potential losses on the policies that he underwrites, a.k.a., show means. In order to show means, P posted a letter of credit issued by Bank Julius Baer (BJB) with Lloyd's. The letter of credit was secured by P's preexisting stock portfolio. The policies that P underwrote for the taxable years 1992 and 1993 incurred losses. As a result of the losses, BJB sold P's stock at a substantial gain during those years. P reported the losses from his underwriting activities…
1Opinion of the Court
HOWARD V. MORE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
More v. Commissioner
No. 4455-99
United States Tax Court
115 T.C. 125; 2000 U.S. Tax Ct. LEXIS 54; 115 T.C. No. 9;
August 15, 2000, Filed
Decision will be entered under Rule 155.
P is an individual underwriter for Lloyd's of London
(Lloyd's). As an underwriter, P is required to demonstrate that
he can cover potential losses on the policies that he
underwrites, a.k.a., show means. In order to show means, P
posted a letter of credit issued by Bank Julius Baer (BJB) with
Lloyd's. The letter of credit was secured by P's preexisting
stoc…
2Cases cited8 opinions
- Federal Deposit Insurance v. MeyerSupreme Court of the United States · 1994
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- HCSC-Laundry v. United StatesSupreme Court of the United States · 1981
- Schaefer v. CommissionerUnited States Tax Court · 1995
- Hillman v. CommissionerUnited States Tax Court · 2000
3 more not listed; retrieve them via the Exa API.