Legal Opinion

Gerling Int'l Ins. Co. v. Commissioner

United States Tax Court

Decided May 27, 1992No. Docket No. 26765-83Published

P reinsured a portion of the casualty insurance business of a Swiss company and received annual statements from that company in respect of the premium income, losses, and expenses of that business. In its Federal income tax returns, P included the data reflected in those statements. R adopted the premium income figures but disallowed the losses and expenses in their entirety.

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P reinsured a portion of the casualty insurance business of a Swiss company and received annual statements from that company in respect of the premium income, losses, and expenses of that business. In its Federal income tax returns, P included the data reflected in those statements. R adopted the premium income figures but disallowed the losses and expenses in their entirety. Held, under sec. 832, I.R.C., P is required to report and prove the gross figures shown on the Swiss company's statements and not simply the net amount of income or loss. Held, further, the statements are admissible in…

1Opinion of the Court

Gerling International Insurance Co., Petitioner v. Commissioner of Internal Revenue, Respondent

Gerling Int'l Ins. Co. v. Commissioner

Docket No. 26765-83

United States Tax Court

98 T.C. 640; 1992 U.S. Tax Ct. LEXIS 46; 98 T.C. No. 44;

May 27, 1992, Filed

Decision will be entered under Rule 155.

P reinsured a portion of the casualty insurance business of a Swiss company and received annual statements from that company in respect of the premium income, losses, and expenses of that business. In its Federal income tax returns, P included the data reflected in those statements. R adopted the premium…

2Cases cited38 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Societe Internationale Pour Participations Industrielles Et Commerciales, S. A. v. RogersSupreme Court of the United States · 1958
  3. Burnet v. HoustonSupreme Court of the United States · 1931
  4. United States v. Moreno L. Keplinger, Paul L. Wright, and James B. PlankCourt of Appeals for the Seventh Circuit · 1985
  5. In Re Korean Air Lines Disaster of September 1, 1983, Korean Air Lines Company, Ltd.Court of Appeals for the D.C. Circuit · 1991

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