Legal Opinion

The Title Guarantee Company v. The United States

United States Court of Claims

Decided October 16, 1970No. 120-69PublishedCited by 2 opinions

1Opinion of the Court

OPINION

SKELTON, Judge:

This is a suit for refund of income taxes in the sum of $42,218.01 and interest paid thereon in the sum of $12,672.80, all in the total sum of $54,890.81, plus any additional interest and amounts as may be legally refundable for the calendar years 1960 through 1964. The facts giving rise to this controversy are fully set forth in the following portions of the stipulation of facts agreed to by the parties and filed herein:

1. The plaintiff, The Title Guarantee Company, is a New York corporation, incorporated by Chapter 382 of the laws of 1882, as amended by Chapter 387 of…

2Cases cited18 opinions

  1. Lovell v. St. Louis Mutual Life InsuranceSupreme Court of the United States · 1884
  2. Commissioner of Int. Rev. v. New Hampshire Fire Ins. Co.Court of Appeals for the First Circuit · 1945
  3. Title & Trust Co. v. CommissionerUnited States Tax Court · 1950
  4. Wayne v. New York Life Ins. Co.Court of Appeals for the Eighth Circuit · 1942
  5. Commissioner of Internal Revenue v. General Reinsurance CorpCourt of Appeals for the Second Circuit · 1951

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3Cited by2 opinions

  1. Continental Insurance v. United StatesUnited States Court of Claims · 1973
  2. Penn Security Life Insurance v. United StatesUnited States Court of Claims · 1975

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