Legal Opinion

Home Title Guaranty Co. v. Commissioner

United States Tax Court

Decided November 16, 1950No. Docket No. 20631Published

Petitioner, a New York corporation, is subject to taxation as an insurance company under section 204 of the Internal Revenue Code. From June 1, 1938, to May 31, 1945, inclusive, petitioner maintained a premium reserve in accordance with a New York statute.

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Petitioner, a New York corporation, is subject to taxation as an insurance company under section 204 of the Internal Revenue Code. From June 1, 1938, to May 31, 1945, inclusive, petitioner maintained a premium reserve in accordance with a New York statute. No part of this reserve constituted unearned premiums under section 204 (b) (5), I. R. C., and no additions to the reserve were deducted by petitioner in its income tax returns prior to the taxable year 1945. On June 1, 1945, pursuant to the New York statute as amended, petitioner segregated and maintained a reinsurance reserve. Additional…

1Opinion of the Court

Home Title Guaranty Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Home Title Guaranty Co. v. Commissioner

Docket No. 20631

United States Tax Court

15 T.C. 637; 1950 U.S. Tax Ct. LEXIS 45;

November 16, 1950, Promulgated

Decision will be entered under Rule 50.

Petitioner, a New York corporation, is subject to taxation as an insurance company under section 204 of the Internal Revenue Code. From June 1, 1938, to May 31, 1945, inclusive, petitioner maintained a premium reserve in accordance with a New York statute. No part of this reserve constituted unearned premiums under section…

2Cases cited2 opinions

  1. Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
  2. Home Title Guaranty Co. v. CommissionerUnited States Tax Court · 1950

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