Legal Opinion

Policy Holders Agency, Inc. v. Commissioner

United States Tax Court

Decided October 10, 1963No. Docket No. 93719Published

Where the constant experience of an accrual basis taxpayer, extending over 16 years, was that no claim against or payment out of a designated liability account had been made, held, that the yearly transfers to such account are determinative of income accrual rather than the subsequent transfer of the entire account to surplus.

1Opinion of the Court

Policy Holders Agency, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Policy Holders Agency, Inc. v. Commissioner

Docket No. 93719

United States Tax Court

41 T.C. 44; 1963 U.S. Tax Ct. LEXIS 40;

October 10, 1963, Filed

Decision will be entered under Rule 50.

Where the constant experience of an accrual basis taxpayer, extending over 16 years, was that no claim against or payment out of a designated liability account had been made, held, that the yearly transfers to such account are determinative of income accrual rather than the subsequent transfer of the entire account to surplus.

F…

2Cases cited28 opinions

  1. Commissioner v. HansenSupreme Court of the United States · 1959
  2. Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
  3. Commissioner of Internal Revenue v. Mnookin's EstateCourt of Appeals for the Eighth Circuit · 1950
  4. Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
  5. Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959

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