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